The document outlines transfer pricing compliance requirements and due dates applicable for Financial Year 2025–26 and the transition to the new Income-tax Rules, 2026 effective from 1 April 2026. It specifies obligations such as maintaining transfer pricing documentation, filing accountant’s reports, master file compliance, and Country-by-Country Reporting (CbCR), along with applicable thresholds and deadlines. Key due dates include 31 October for documentation and reporting forms, 30 November for master file filing, and 12 months from the end of the parent entity’s accounting year for CbCR. The new regime introduces revised forms replacing existing ones and implements graded penalties for delays, particularly for accountant’s reports. Penalties continue for non-compliance, including percentages of transaction value and daily penalties for delayed CbCR filings. The framework also includes safe harbour rules and introduces a new block assessment scheme from Tax Year 2026–27. Old rules remain applicable for FY 2025–26, ensuring a transition period between regulatory regimes.
India Transfer Pricing- Due Dates for Compliance
Financial Year 2025-26 / Tax Year 2026-27
Compliance |
Old Form (Rules 1962) |
New Form (Rules 2026) |
Threshold / Applicability |
Due Date |
Penalty- Income Tax Act, 1961 |
Penalty- Income Tax Act, 2025 |
| Annual TP Documentation & Reporting | ||||||
Maintaining TP documentation (Local File) |
— |
— |
International transactions > INR 1 Cr.SDT > INR 20 Cr. |
31 October following the end of FY |
2% of the value of each International Transaction or SDT [Section 271AA(1)] |
2% of the value of each International Transaction or SDT [Section 442(1)] |
Accountant’s Report |
Form 3CEB (FY 2025-26) |
Form 48 (from TY 2026-27) |
Any international transaction / SDT- no minimum threshold for international transaction;SDT > INR 20 Cr. |
31 October following the end of FY |
INR 1,00,000[Section 271BA] |
Automatic and Graded Fee: • INR 50,000 (Initial delay of One Month)• INR 1,00,000 (Beyond One Month)[Section 428(d)] |
Master File-Intimation by Designated Constituent Entity |
Form 3CEAB (FY 2025-26) |
Form 57 (from TY 2026-27) |
Multiple constituent entities in India belonging to same group |
31 October following the end of FY |
INR 5,00,000 for failure to furnish[Section 271AA(2)] |
INR 5,00,000 for failure to furnish[Section 442(2)] |
Master File- Part A & B Filing |
Form 3CEAA (FY 2025-26) |
Form 56 (from TY 2026-27) |
Part A: every constituent entity PartB: International transaction > INR 50 Cr and group turnover > INR 500 Cr |
30 November following the end of FY |
||
| Country-by-Country Reporting (CbCR) | ||||||
CbCR Intimation |
Form 3CEAC (FY 2025-26) |
Form 58 (from TY 2026-27) |
Group revenue > INR 6,400 Cr |
2 months prior to due date for CbCR report.CbCR report due: 12 months from end of parent’s accounting year |
INR 5,000/day (up to 1 month);INR 15,000/day (beyond 1 month);INR 50,000/day after penalty order;INR 5,00,000 for inaccurate report[Section 271GB] |
INR 5,000/day (up to 1 month);INR 15,000/day (beyond 1 month);INR 50,000/day after penalty order;INR 5,00,000 for inaccurate report[Section 459] |
CbCR — Special Cases (No Exchange Agreement / Systematic Failure) |
Form 3CEAE (FY 2025-26) |
Form 60 (from TY 2026-27) |
Where no agreement for exchange of CbCR or systematic failure |
Same as CbCR intimation timeline |
||
CbCR Filing |
Form 3CEAD (FY 2025-26) |
Form 59 (from TY 2026-27) |
Only when parent entity or alternate reporting entity is in India |
12 months from end of reporting accounting year |
||
| Safe Harbour Rules (SHR) | ||||||
Safe Harbour Application- International Transactions (Non-IT) |
Form 3CEFA (FY 2025-26) |
Form 49 filed with AO (from TY 2026-27) |
Entities meeting eligible business activity criteria & thresholds (non-IT)Block of 3 TYs; application filed each year |
On or before return filing due date (typically 30 November). |
– |
– |
Safe Harbour Application- IT / ITeS Services |
Form 3CEFA (FY 2025-26) |
Form 49 filed with DGIT Systems (from TY 2026-27) |
IT/ITeS entities; OP/OC ≥ 15.5% (revenue ≤ INR 2,000 Cr); valid for 5 consecutive TYs |
On or before return filing due date (typically 30 November) |
– |
– |
Safe Harbour Application- SDT |
Form 3CEFB (FY 2025-26) |
Form 49 (from TY 2026-27) |
Entities meeting eligible SDT criteria & specified thresholds |
– |
– |
|
| Block Assessment Scheme (New- Applicable from TY 2026-27) | ||||||
Block Assessment Opt-In (Taxpayer Election) |
Not applicable under old rules |
Form 46 |
Taxpayer opting for 3-year block TP assessment (Base Year + 2 subsequent TYs) |
1 April- 30 June of the FY following the third TY |
Not applicable (voluntary scheme) |
Not applicable (voluntary scheme) |
Accountant’s Certificate for Block Assessment |
— |
Form 47 |
Certifies no change in nature of international transactions & business conditions for Years 2 & 3 vs. Base Year |
Filed together with Form 46 |
Non-filing invalidates block assessment election |
Non-filing invalidates block assessment election |
Note 1: The new Income-tax Rules, 2026 (and renamed forms) come into effect from 1 April 2026, i.e., Tax Year 2026-27 / AY 2027-28 onwards. Old forms under Income-tax Rules, 1962 continue to apply for FY 2025-26 / AY 2026-27 and earlier years.
Note 2: Tax year refers to 12-month period of the financial year commencing from 1st April to 31st March.
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