Transfer pricing update

Form 3CEB due date: still 31 October 2026

CBDT’s Circular 7/2026 gave audit cases until 21 October and 21 November — but it didn’t cover transfer-pricing cases. If your company has international transactions with group entities, plan for 31 October.

The dates for AY 2026-27

FilingDue date
Accountant’s report on international / specified domestic transactions (Form 3CEB)31 October 2026
Tax audit report for transfer-pricing cases31 October 2026
Income-tax return for transfer-pricing cases30 November 2026

The circular extended only the category due on 31 October; a trade-body request for more time wasn’t reflected in it. Penalty for not furnishing the report under the 1961 Act is ₹1 lakh.

Who files Form 3CEB

  • Indian subsidiaries billing a foreign parent — GCCs, offshore teams, captive centres.
  • Indian parents with foreign subsidiaries: loans, guarantees, service charges, royalties.
  • Startups with a Delaware parent — see India–US transfer pricing.

From next year

For AY 2026-27 (income of 2025-26) the report is still under the 1961 Act. From tax year 2026-27 the Income-tax Act, 2025 applies, with the report renumbered under the Income-tax Rules, 2026 and due before the return due date.

Frequently asked questions

Is the Form 3CEB due date extended for AY 2026-27?
No. CBDT Circular 7/2026 extended only non-transfer-pricing audit cases; Form 3CEB remains due on 31 October 2026 and the ITR for transfer-pricing cases on 30 November 2026.
Who needs to file Form 3CEB?
Taxpayers with international transactions or specified domestic transactions with associated enterprises — for example an Indian subsidiary charging its foreign parent for services.

Please note: this guide is general information based on the rules as they stood on the review date above. Regulations and RBI/CBDT procedures change often — please get advice on your specific facts before acting.

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