Transfer Pricing Compliance Calendar: Deadlines, Forms & Penalties (FY 2025-26)
Transfer pricing compliance in India runs on a strict filing calendar separate from your regular income tax return covering the transfer pricing audit report, Master File, and Country-by-Country Report. Missing any one of these triggers penalties independent of and in addition to any income tax assessment. This page sets out the current filing dates, applicable forms, and penalty provisions for FY 2025-26 (AY 2026-27). For a broader introduction to what transfer pricing is and how the arm’s length principle applies, see our overview guide.
Transfer Pricing Compliance Calendar: FY 2025-26 Key Dates
| S. No. | Compliance | Form | Due Date |
| 1. | Transfer Pricing Audit Report [Section 92E] | Form 3CEB | 31st October 2026 |
| 2. | Income Tax Return for taxpayers with TP audit obligations [Section 139(1)] | ITR | 30th November 2026 |
| 3. | Master File [Section 92D(4)] | Form 3CEAA | 30th November 2026 |
| 4. | CbCR Intimation by resident constituent entity [Section 286(1), Rule 10DB(2)] | Form 3CEAC | 31st January 2027 |
| 5. | Country-by-Country Report [Section 286(2), Rule 10DB(3)] | Form 3CEAD | 31st March 2027 |
Dates above assume a standard 1 April–31 March accounting year. Groups following a different accounting year should recalculate Forms 3CEAC and 3CEAD deadlines accordingly, as both are tied to the group’s own accounting year-end rather than a fixed calendar date.
Form 3CEB: Transfer Pricing Audit Report
Every taxpayer that has entered into an international transaction with an associated enterprise or a specified domestic transaction exceeding ₹20 crore under Section 92BA must obtain and file a transfer pricing audit report in Form 3CEB, certified by a Chartered Accountant. Unlike the general tax audit relaxations occasionally granted for other categories of assessees, Form 3CEB’s due date has consistently remained fixed at 31st October. The Income Tax Department does not extend this deadline even when other audit-related due dates are relaxed. Taxpayers required to file Form 3CEB then get an extended income tax return due date of 30th November, one month later than the standard audit-case ITR deadline.
TP Documentation & Benchmarking
Beyond Form 3CEB itself, Section 92D(1) requires taxpayers to maintain contemporaneous transfer pricing documentation, the study report supporting the arm’s-length nature of related-party pricing. This documentation has no fixed filing deadline; it must be maintained and furnished to tax authorities on request. For a full breakdown of what this documentation should contain and how it differs from master file requirements, see our guide to Master File vs Local File requirements.
Master File: Form 3CEAA
Part A of Form 3CEAA must be filed by every constituent entity of an international group, regardless of transaction value. Part B, the detailed disclosure of global operations, value drivers, and intercompany financing, applies only where the consolidated group revenue exceeds ₹500 crore in the preceding accounting year and either the aggregate value of international transactions exceeds ₹50 crore or transactions involving intangible property exceed ₹10 crore. The due date aligns with the ITR due date for TP-audit cases: 30th November 2026 for AY 2026-27. This sits within the broader three-tier transfer pricing documentation framework.
Country-by-Country Reporting: Forms 3CEAC & 3CEAD
CbCR applies where the MNE group’s consolidated revenue exceeds ₹6,400 crore (approximately EUR 750 million). A resident constituent entity must file an intimation in Form 3CEAC two months before the parent entity’s CbCR filing deadline. Where the Indian entity is itself the parent or the designated alternate reporting entity, the report itself is filed in Form 3CEAD within 12 months of the end of the reporting accounting year.
Penalties for Missing Transfer Pricing Deadlines
| S. No. | Non-Compliance | Penalty |
| 1. | Non-filing of Form 3CEB [Section 92E] | ₹1,00,000 [Section 271BA] |
| 2. | Failure to maintain or furnish TP documentation [Section 92D(1)] | 2% of the value of each international transaction [Section 271AA(1)] |
| 3. | Non-filing of Master File, Form 3CEAA [Section 92D(4)] | ₹5,00,000 [Section 271AA(2)] |
| 4. | Failure to furnish CbCR, Form 3CEAD [Section 286(2)] | ₹5,000/day (delay up to 1 month); ₹15,000/day (delay beyond 1 month) [Section 271GB(1)] |
Why Transfer Pricing Compliance Requires Ongoing Attention
Transfer pricing compliance is not a once-a-year filing exercise. It requires periodic updates to documentation, alignment with changing regulations, monitoring of intercompany transactions, and ongoing benchmarking. Businesses commonly face challenges such as limited internal expertise, complexity in functional and risk analysis, difficulty selecting appropriate comparables, and evolving regulatory expectations, all of which compound the risk of missing a deadline or filing an inadequate report.
How MBG Helps You Stay Ahead of TP Deadlines
MBG provides end-to-end transfer pricing compliance support, including documentation and benchmarking, Master File and CbCR filing, and strategic advisory aligned with evolving global regulations so your filings are accurate, defensible, and on time.