Transfer Pricing, Master File and CbCR Compliance: FY 2021-22 Deadlines and Penalties
For taxpayers engaged in international transactions, transfer pricing compliance extends beyond benchmarking and documentation. It also involves timely filing of prescribed forms, including transfer pricing certification, Master File reporting, and Country-by-Country Reporting (CbCR) compliances. For FY 2021-22, these compliance timelines were particularly important for constituent entities of international groups and taxpayers with cross-border related party transactions.
While the due dates below relate specifically to FY 2021-22, the underlying compliance framework continues to remain relevant for multinational groups operating in India. The Income Tax Department continues to recognize Form 3CEAA for Master File reporting and Form 3CEAD for Country-by-Country Reporting under the current transfer pricing framework.
Due Dates of Compliances for FY 2021-22
| S. No. | Particulars | Due Dates |
| 1. | Transfer Pricing Certification, i.e. filing of Form 3CEB [Section 92E] |
31st October, 2022 |
| 2. | Master File compliance, i.e. filing of Form 3CEAA [Section 92D(4)] |
30th November, 2022 |
| 3. | Country-by-Country Reporting (CbCR) compliance, i.e. filing of intimation in Form 3CEAC by a resident constituent entity of an international group [Section 286(1) read with Rule 10DB(2)] |
31st January, 2023 |
| 4. | Country-by-Country Reporting (CbCR) compliance, i.e. filing of Form 3CEAD [Section 286(2) read with Rule 10DB(3)] |
31st March, 2023 |
Penalties for Non-Compliances
| S. No. | Particulars | Penalties |
| 1. | Transfer Pricing Certification, i.e. non-filing of Form 3CEB [Section 92E] |
Rs. 1,00,000/- [Section 271BA] |
| 2. | Transfer Pricing Documentation, i.e. failure to furnish the Transfer Pricing Study Report [Section 92D(1)] |
2% of the value of each international transaction [Section 271AA(1)] |
| 3. | Master File compliance, i.e. non-filing of Form 3CEAA [Section 92D(4)] |
Rs. 5,00,000/- [Section 271AA(2)] |
| 4. | Country-by-Country Reporting (CbCR) compliance, i.e. failure to furnish the report in Form 3CEAD [Section 286(2)] |
Rs. 5,000/- per day where the failure does not exceed one month, and Rs. 15,000/- per day where the failure continues beyond one month [Section 271GB(1)] |
Compliance Perspective
These timelines and penalties highlight that transfer pricing compliance in India is not limited to preparing a study report. It also requires disciplined execution of filing obligations across certification, Master File reporting, and CbCR-related disclosures. For multinational groups, non-compliance can create both penalty exposure and wider scrutiny risk.
From a practical standpoint, this makes transfer pricing compliance closely linked with broader taxation advisory, especially in areas involving transfer pricing in India, international tax services, and cross-border transaction advisory.
For additional reference, the official Income Tax Department material continues to reflect Form 3CEAA as the notified Master File form and section 271GB-based penalties for CbCR failures.