Accountant's transfer pricing report: Form 48 from tax year 2026-27, Form 3CEB for FY 2025-26

Who needs a transfer pricing report?

Any person that enters into an international transaction with an associated enterprise must obtain an accountant's report. An Indian subsidiary paying royalty or service fees to its foreign parent, buying goods from a group company, or receiving a loan from an overseas affiliate is a typical case. There is no minimum value for international transactions.

Specified domestic transactions, such as certain transactions between related domestic entities where one claims a profit-linked deduction, also need a report when their aggregate value in the year exceeds ₹20 crore. Many purely domestic groups therefore fall outside the regime.

From Form 3CEB to Form 48

For FY 2025-26, the report is Form 3CEB under section 92E of the 1961 Act. It is due one month before the return due date, which for transfer pricing cases is 30 November 2026, so Form 3CEB is due by 31 October 2026. The September 2026 extension for audit cases did not cover transfer pricing taxpayers.

From tax year 2026-27, the Income-tax Rules 2026 replace Form 3CEB with Form 48. Professional commentary describes Form 48 as more structured, with benchmarking details, comparables, ranges and adjustments in the form itself, mapping of advance pricing agreements, and confirmation that transfer pricing documentation is maintained.

What data do you need?

The report is only as strong as the transfer pricing study behind it, and officers read both together. Before the accountant signs, the following should be ready and consistent with the audited financial statements.

• List of associated enterprises and the basis of association
• Transaction-wise values from the books, reconciled to the financial statements
• Method used for each transaction: CUP, resale price, cost plus, TNMM, profit split or other
• Benchmarking analysis with comparables and arm's length range
• Advance pricing agreement details, if any
• Contemporaneous documentation maintained under the rules

Related filings and common errors

Large multinational groups may also have master file and country-by-country reporting obligations, which have their own forms and deadlines. These are separate from the accountant's report and should be tracked on a group calendar.

Common errors include omitting transactions such as reimbursements, guarantees or deemed international transactions through third parties, reporting values that do not match the books, choosing a method without justification, and filing the report after the return. A missing or wrong report weakens the defence in a transfer pricing audit, where adjustments can be large. Refogo's partner professionals can coordinate transfer pricing compliance for Indian subsidiaries.

Consequences of not filing

Apart from the penalty or fee, failure to file the report can lead to a reference to the Transfer Pricing Officer with no documented position to defend, and to penalties for failure to maintain documentation. Adjustments made in assessment also trigger secondary adjustment rules where the excess money is not repatriated.

Because the report must be filed before the return, and the return due date for these cases is fixed in the law, plan the benchmarking during the year rather than in October, when comparable databases and reviewers are busiest.

Step by step

1. 1Identify associated enterprises

   List group entities and all transactions with them during the year.

2. 2Prepare the TP study

   Select methods and benchmark each transaction to establish arm's length prices.

3. 3Reconcile with accounts

   Tie transaction values to audited financial statements.

4. 4CA files the report

   The CA uploads Form 3CEB for FY 2025-26, or Form 48 for tax year 2026-27.

5. 5Accept and file the return

   Accept the report on the portal, then file the return by its due date.