Transfer pricing report due date 2026: Form 3CEB by 31 October, Form 48 first filed in 2027

If you read that the deadlines moved in September, that extension applies to companies with no transfer pricing report. Circular No. 07/2026 extends only the second row of the return-date table, for companies "where the provisions of section 92E do not apply".

When is the transfer pricing report due in 2026?

For the financial year (FY) 2025-26, which ended on 31 March 2026, the report is due by 31 October 2026. The report is often called the transfer pricing audit, and it is separate from the company's tax audit report. Indian tax law assesses that income in assessment year (AY) 2026-27, the year named on the forms and on the Income Tax Department's e-Filing portal.

The date follows from two provisions of the Income-tax Act 1961. Section 92F(iv) makes the report due on "the date one month prior to the due date for furnishing the return of income", and the table in Explanation 2 to section 139(1) gives a return date of 30 November to any taxpayer "where the provisions of section 92E apply". The tax audit report under section 44AB follows the same one-month rule, so it is due on 31 October 2026 as well. The Central Board of Direct Taxes (CBDT) prints both dates in its transition FAQ: 31 October 2026 for the audit report in transfer pricing cases, and 30 November 2026 for their return.

Some published calendars give 30 November for Form 3CEB, the date of the return itself. The report is due one month earlier.

Did the September 2026 extension move the transfer pricing deadline?

For a company that files a transfer pricing report, the dates have not moved. On 28 September 2026 CBDT issued Circular No. 07/2026, which extends the AY 2026-27 return date from 31 October 2026 to 21 November 2026 "for the persons referred in sl.no.2 of the table below Explanation 2 to sub-section (1) of section 139", and moves their tax audit report date with it.

Serial number 2 (Sl. No. 2) of that table is the row for companies and audited assessees (taxpayers whose accounts must be audited) "where the provisions of section 92E do not apply". A company that must furnish a section 92E report sits in Sl. No. 1, the row "where the provisions of section 92E apply". The circular never mentions transfer pricing; the row it names decides who gets the extra time.

If your company had no international transaction in FY 2025-26 and no specified domestic transactions above Rs 20 crore (a crore is ten million rupees), it files no section 92E report and sits in Sl. No. 2. For that company the circular does move the dates: the tax audit report to 21 October 2026 and the return to 21 November 2026.

Is it Form 3CEB or Form 48 this year?

This year's report is Form 3CEB. The Income-tax Act 2025 came into force on 1 April 2026, and CBDT's transition FAQ says a return for FY 2025-26 "relates to a tax year beginning before 1st April, 2026 and is therefore governed entirely by the old Act". The same FAQ says the e-Filing portal carries the old forms for AY 2026-27 and earlier and the new forms for tax year 2026-27 onwards.

Form 48 is the successor to Form 3CEB from tax year 2026-27, the year that began on 1 April 2026. CBDT's Form 48 FAQ maps the change: section 92E becomes section 172 of the Income-tax Act 2025, Rule 10E becomes Rule 85 of the Income-tax Rules 2026, and Form 3CEB becomes Form No. 48. The transactions your company has entered into with its group since 1 April 2026 will be reported on Form 48, first filed in 2027.

Form 48 is due one month before the return due date, and for tax year 2026-27 a company that files a transfer pricing report has a return due date of 30 November 2027, so the first Form 48 is due by 31 October 2027. The form is filed only online, has six parts, and asks in Part E for the arm's length price determination for each transaction. Keep this year's intercompany records transaction by transaction, so the first Form 48 can be prepared from them.

Which companies must file a transfer pricing report?

Section 92E requires a report from every person "who has entered into an international transaction or specified domestic transaction" in the year. An international transaction is a transaction between associated enterprises, either or both of them non-resident, such as a purchase, sale or lease of property, the provision of services, or lending or borrowing money. A foreign parent that holds 26% or more of the voting power in your company is an associated enterprise under section 92A, so those dealings with it are international transactions.

There is no minimum amount. The Income Tax Department's transfer pricing guide says the rules are "applicable to all international transactions irrespective of amount involved". The Rs 1 crore figure some guides give as a threshold is a documentation relief in Rule 10D(2): at or below it, the company does not have to keep the detailed records listed in Rule 10D(1), it must still be able to show that its income from those transactions was computed at arm's length, and Form 3CEB is still due.

Specified domestic transactions, a category defined in section 92BA, count only when their total for the year exceeds Rs 20 crore.

What does a late or missing report cost?

For this year's report, the risk is a penalty under section 271BA of the Income-tax Act 1961: if a company fails to furnish the report, the Assessing Officer may direct it to pay "a sum of one hundred thousand rupees", written in India as Rs 1,00,000. Section 273B gives a defence: no penalty applies if the company proves reasonable cause for the failure. The 1961 Act's penalty still applies because section 536(2)(d) of the Income-tax Act 2025 keeps penalties for tax years that began before 1 April 2026 under the repealed Act.

From tax year 2026-27 the penalty becomes a fee. The Finance Act 2026 omitted section 447 of the Income-tax Act 2025, the penalty for failing to furnish a section 172 report, with effect from 1 April 2026, and put a fee in section 428(d).

A missing report also leaves the transactions open to examination: a transaction left out of the report can still be taken up by the Transfer Pricing Officer if it comes to notice during the proceedings (section 92CA(2B)).

What else is due with the transfer pricing report?

A subsidiary that your parent consolidates in its accounts is a constituent entity of an international group under section 286 of the 1961 Act, which brings it into the group filings: the Master File and, for the largest groups, the Country-by-Country report.

Rule 10DA(3) requires every constituent entity to furnish Part A of Form 3CEAA, the Master File form, even when the Master File thresholds are not met. Form 3CEAA is due on or before the return due date, and a company that files a transfer pricing report has a return due date of 30 November 2026, so Part A is due by 30 November 2026. A small subsidiary can file Form 3CEB on time and still miss Part A.

The Country-by-Country rules apply only where the group's total consolidated revenue for the preceding accounting year exceeds Rs 6,400 crore (Rule 10DB). For such a group, the Form 3CEAC date depends on the parent's year end: for a group whose year ended on 31 December 2025, the report is due on 31 December 2026, so Form 3CEAC is due on 31 October 2026. An Indian subsidiary files the report itself only in the cases section 286(4) lists, which depend on the parent's country.

The Income-tax Rules 2026 keep these thresholds and keep Part A compulsory below them. Foreign ownership also brings yearly filings under the Foreign Exchange Management Act (FEMA); see the FEMA filings a foreign-owned company makes each year.

What does the finance team need to do before 31 October?

Step 1: List the year's transactions with the group

List every transaction with the parent and other group companies abroad in FY 2025-26, with the amounts in the books: purchases, sales, services, the use of intangible property and loans. One such transaction is enough to require the report.

Step 2: Ask the parent for the group facts

Ask the parent for the group's consolidated revenue, its accounting year end and the entity that files its Country-by-Country report. The Master File thresholds, the Country-by-Country threshold and the Form 3CEAC date all depend on them.

Step 3: Have the documentation ready by 31 October 2026

Rule 10D(4) of the Income-tax Rules 1962 says the documentation behind the report should exist by the specified date, so the records must be in place by the day the report is due.

Step 4: Check both digital signatures

Your chartered accountant and the company each need a valid and active Digital Signature Certificate (DSC).

Step 5: Assign Form 3CEB to your chartered accountant

Following the e-Filing portal's Form 3CEB FAQ, the company adds its chartered accountant on the portal and assigns Form 3CEB to them. The accountant completes the form and files it with a digital signature and a Unique Document Identification Number (UDIN) from the Institute of Chartered Accountants of India (ICAI).

Step 6: Approve the form

The filing is complete only once the company approves and verifies the form its accountant uploaded. The portal allows one original Form 3CEB for each Permanent Account Number (PAN) and assessment year, and offers a revised filing for later changes.

LegalJini handles transfer pricing work through a partner firm it has worked with for more than 20 years. To discuss this year's report, write to LegalJini by email or use the callback form on the website; LegalJini replies to every enquiry within 12 hours.