The International Taxation Committee of the Institute of Chartered Accountants of India (ICAI) has released the “Handbook on Year-End Transfer Pricing Compliance Checklists”, providing a structured and implementation-oriented guide for taxpayers and professionals dealing with year-end Transfer Pricing (“TP”) compliances for Financial Year 2025-26 / Assessment Year 2026-27. The Handbook has been prepared with reference to the Income-tax Act, 1961, as amended by the Finance Act, 2026.
Practical Guide covering the complete TP compliance cycle
The Handbook seeks to provide a consolidated practical framework for key Transfer Pricing obligations, including the Accountant’s Report in Form No. 3CEB, contemporaneous Transfer Pricing documentation, Master File and Country-by-Country Reporting (CbCR). ICAI has clarified that the publication is intended to complement the statutory framework through practical guidance, compliance checklists, documentation requirements, information-gathering templates and transaction-specific considerations rather than merely reproducing statutory provisions.
Form No. 3CEB due by October 31, 2026
Under Section 92E read with Rule 10E, a taxpayer entering into an international transaction is required to furnish the Accountant’s Report in Form No. 3CEB, irrespective of the transaction value. In the case of Specified Domestic Transactions (“SDTs”), the reporting requirement applies where the aggregate value exceeds ₹20 crore, subject to Section 92BA. For FY 2025-26, the Handbook specifies October 31, 2026 as the due date for furnishing Form No. 3CEB. Failure to furnish the report may attract a penalty of ₹1,00,000 under Section 271BA.
Contemporaneous Transfer Pricing Documentation assumes critical importance
The Handbook reiterates the requirement under Section 92D read with Rule 10D for maintenance of prescribed TP documentation where the aggregate value of international transactions exceeds ₹1 crore, or SDTs exceed ₹20 crore, during the financial year. Such documentation should be maintained contemporaneously and be in place by the applicable due date for furnishing Form No. 3CEB/return of income. Failure to maintain prescribed documentation may attract penalty under Section 271AA(1) equal to 2% of the value of each relevant transaction, while failure to furnish information or documents requisitioned under Section 92D(3) may attract penalty under Section 271G, subject to Section 273B.
Master File – Form No. 3CEAA Part A due by November 30, 2026
Under Section 92D(4) read with Rule 10DA, Form No. 3CEAA (Part A) applies to every constituent entity of an international group entering into an international transaction during the financial year. The Handbook specifies November 30, 2026 as the due date. Non-compliance may attract a penalty of ₹5 lakh under Section 271AA(2).
Form No. 3CEAA Part B – ₹500 crore group-revenue threshold
Part B of Form No. 3CEAA becomes applicable where the consolidated group revenue exceeds ₹500 crore and either the aggregate value of international transactions exceeds ₹50 crore, or international transactions relating to intangible property exceed ₹10 crore. The due date for FY 2025-26 is stated as November 30, 2026, with penalty exposure of ₹5 lakh under Section 271AA(2) for non-compliance.
Form No. 3CEAB intimation due by October 31, 2026
Where more than one constituent entity of an international group is resident in India and the group is required to furnish the Master File, Form No. 3CEAB is required under Section 92D(4) read with Rule 10DA for designating the constituent entity responsible for furnishing the Master File. The Handbook specifies October 31, 2026 as the relevant due date.
Country-by-Country Reporting threshold fixed at ₹6,400 crore
The Handbook states that Form No. 3CEAD, relating to Country-by-Country Reporting under Section 286(2)/(4) read with Rule 10DB, applies where the consolidated group revenue of the international group for the preceding accounting year exceeds ₹6,400 crore, subject to Section 286. The CbCR is generally required to be furnished within 12 months from the end of the reporting accounting year. For an accounting year ending March 31, 2026, the Handbook illustrates the filing date as March 31, 2027.
The Handbook further notes that where the Parent Entity or Alternate Reporting Entity files the CbCR in a jurisdiction having an effective automatic exchange arrangement with India, filing of the report in India may not be required. Failure to comply with the prescribed CbCR requirements can attract penalties under Section 271GB, including penalties for inaccurate information and continuing default in furnishing the report.
CbCR Notification in Form No. 3CEAC – 10-month timeline
Under Section 286(1) read with Rule 10DB, an Indian constituent entity may be required to furnish Form No. 3CEAC where the Parent Entity or Alternate Reporting Entity furnishes the CbCR outside India. The notification is required within 10 months from the end of the reporting accounting year. The Handbook illustrates October 31, 2026 as the due date where the reporting accounting year ended on December 31, 2025.
Form No. 3CEAE: no specific statutory due date prescribed
Where multiple constituent entities of an international group are resident in India and one entity is designated to furnish the CbCR on behalf of all Indian constituent entities, Form No. 3CEAE is relevant under Section 286(4) read with Rule 10DB(5). Significantly, the Handbook states that no specific due date or specific penalty has been prescribed under the Act or Rules for Form No. 3CEAE.
Form 3CEB reporting extends across wide range of international transactions
The Handbook explains that Part B of Form No. 3CEB covers international and deemed international transactions and broadly includes transactions involving tangible property, intangible property, capital financing including lending, borrowing and guarantees, provision of services, and business restructuring or reorganisation. Part C deals with Specified Domestic Transactions.
Focus shifts from mere filing to “year-end TP readiness”
A key feature of the Handbook is its emphasis on undertaking a systematic year-end review rather than treating Transfer Pricing as merely a return-filing exercise. Taxpayers are encouraged to evaluate transaction terms, arm’s-length implications, supporting agreements and documentation, functional and economic analyses, benchmarking and consistency of disclosures across Form No. 3CEB, financial statements, TP Study, Master File and CbCR. ICAI notes that a structured year-end process can help taxpayers proactively identify TP issues and reduce the risk of adjustments and subsequent disputes.
Important compliance takeaway
With October 31 and November 30, 2026 emerging as important Transfer Pricing compliance dates for FY 2025-26, affected taxpayers should immediately undertake a transaction-wise reconciliation of related-party dealings, identify all Associated Enterprises, review inter-company agreements, complete benchmarking and arm’s-length analyses and evaluate the applicability of Form Nos. 3CEB, 3CEAA, 3CEAB, 3CEAC, 3CEAD and 3CEAE, wherever applicable.
The Handbook can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/09/ICAI-Handbook.pdf
