Master File & CbCR Filing for AY 2026-27: Upcoming Due Dates, Applicability, Forms & FAQs

For Indian companies and other entities forming part of multinational groups, transfer pricing compliance does not end with Form 3CEB. Depending on the size of the international group, the value and nature of international transactions, the location of the ultimate parent entity and the group’s reporting year, separate requirements may arise for the Master File and Country-by-Country Reporting (CbCR).

For FY 2025-26 / Assessment Year 2026-27, the approaching filing season makes it important to separately evaluate Form 3CEAA, Form 3CEAB, Form 3CEAC, Form 3CEAD and Form 3CEAE, apart from Form 3CEB and the income-tax return.

This guide explains the Indian compliance framework, thresholds, due dates, foreign-parented group obligations, penalties, practical examples and frequently asked questions relevant to AY 2026-27.

1. Important AY 2026-27 transfer pricing compliance dates at a glance

Compliance	Form	Indicative due date / rule for AY 2026-27
Accountant’s report for international / specified domestic transactions	3CEB	31 October 2026 where the section 139(1) return due date is 30 November 2026.
Intimation for designated Indian entity filing a common Master File	3CEAB	30 days before Form 3CEAA; ordinarily 31 October 2026 where 3CEAA is due 30 November 2026.
Master File	3CEAA	On or before the applicable section 139(1) return due date; ordinarily 30 November 2026 in a section 92E transfer-pricing case.
Income-tax return for a section 92E case	Applicable ITR	30 November 2026.
CbCR notification where foreign parent follows 31 December 2025 year-end and CbCR provisions apply	3CEAC	31 October 2026, being two months before the 31 December 2026 CbCR due date.
CbCR for a reporting accounting year ending 31 December 2025	3CEAD	31 December 2026.

Important: Master File and CbCR do not necessarily follow the same due date. CbCR works with the reporting accounting year of the international group, which may be different from the Indian entity’s April-March financial year.

2. AY 2026-27 continues under the Income-tax Act, 1961

AY 2026-27 relates to income earned during FY 2025-26. This assessment year continues to be administered under the Income-tax Act, 1961. Accordingly, the existing transfer pricing forms such as 3CEB, 3CEAA, 3CEAB, 3CEAC, 3CEAD and 3CEAE remain relevant for the AY 2026-27 compliance cycle.

This distinction is important because the new Income-tax Act framework applies prospectively to the tax year beginning 1 April 2026. Professionals preparing FY 2025-26 / AY 2026-27 filings should therefore not mix the new statutory numbering with the forms and provisions applicable to this assessment year.

3. The three-tier international transfer pricing documentation framework

For a multinational group, transfer pricing documentation can broadly be understood in three layers:

Layer	Purpose	Indian compliance
Local File / TP Documentation	Supports the arm’s length nature of the Indian entity’s international transactions, including functions, assets, risks, method selection and benchmarking.	Section 92D read with Rule 10D.
Master File	Provides a group-level picture of the MNE’s business, ownership, value drivers, intangibles, financing and global transfer pricing policies.	Form 3CEAA under Rule 10DA.
Country-by-Country Report	Provides jurisdiction-wise information on revenues, profits, taxes, employees, capital, accumulated earnings and tangible assets.	Form 3CEAD under section 286 / Rule 10DB, with related notification forms.

Form 3CEB is a separate accountant’s report under section 92E. Filing Form 3CEB does not automatically satisfy the Local File, Master File or CbCR requirements.

Practical point: The Indian entity should maintain one consistent transfer pricing story. The transaction description, functional profile, group structure, ownership of intangibles, financing arrangements and profitability reflected in the TP study, Form 3CEB, Master File, CbCR and financial statements should be reconciled before filing.

4. What is a Master File?

The Master File is a high-level document intended to give tax authorities an overview of the multinational group as a whole. Unlike an Indian Local File, it is not limited to a single Indian entity or a single related-party transaction.

For AY 2026-27, the prescribed Indian Master File form is Form 3CEAA. It contains two distinct parts:

Part	Broad requirement
Part A	Basic information regarding the assessee, international group and constituent entities operating in India.
Part B	Detailed group-level information including ownership structure, businesses, supply chains, service arrangements, intangibles, financing, financial statements, APAs and tax rulings.

The distinction between Part A and Part B is one of the most important practical aspects of Master File compliance.

5. Who must file Form 3CEAA Part A?

Part A of Form 3CEAA is required to be furnished by a constituent entity of an international group even where the monetary thresholds for detailed Part B documentation are not satisfied.

This means that an Indian subsidiary or other Indian constituent entity should not conclude that Form 3CEAA is irrelevant merely because:

• the Indian entity is small;
• its international transactions are below ₹50 crore;
• its intangible transactions are below ₹10 crore;
• the international group’s consolidated revenue is below ₹500 crore; or
• detailed Master File Part B is not applicable.

Part A and Part B must therefore be evaluated separately.

6. When is detailed Master File — Form 3CEAA Part B — applicable?

Detailed Master File information under Part B is triggered where both the group-revenue condition and one of the transaction-value conditions are satisfied.

Condition 1 — consolidated group revenue

The consolidated group revenue of the international group for the relevant accounting year must exceed:

₹500 crore

Condition 2 — value of international transactions

In addition, either of the following must be satisfied:

Aggregate international transactions exceed ₹50 crore

OR

International transactions involving purchase, sale, transfer, lease or use of intangible property exceed ₹10 crore.

Illustrative applicability table

Consolidated group revenue	Total international transactions	Relevant intangible transactions	3CEAA Part B?
₹450 crore	₹100 crore	Nil	No
₹600 crore	₹40 crore	₹5 crore	No
₹600 crore	₹55 crore	Nil	Yes
₹600 crore	₹20 crore	₹12 crore	Yes
₹1,200 crore	₹35 crore	₹7 crore	No

The ₹500 crore group-revenue threshold alone does not trigger Part B. One of the transaction thresholds must also be crossed.

7. Which accounting year is relevant for the ₹500 crore Master File threshold?

For Master File purposes, Rule 10DA refers to the consolidated group revenue of the international group as reflected in its consolidated financial statements for the relevant accounting year.

The relevant accounting year may not necessarily be the Indian April-March financial year. For a foreign-parented international group, the accounting period followed by the parent under the applicable law or accounting framework in its jurisdiction may be relevant.

If the consolidated group revenue is in foreign currency, the prescribed conversion rule should be applied using the appropriate telegraphic transfer buying rate for the relevant date under Rule 10DA.

8. What does Form 3CEAA Part B contain?

Where Part B applies, substantial group-level information is required. Broadly, the Master File covers the following areas:

Area	Typical information required
Group entities	List of international group entities and their addresses.
Legal and ownership structure	Chart showing legal status and ownership structure of the group.
Business description	Nature of major businesses, important profit drivers and major geographic markets.
Supply chain	Description of the supply chain for significant products and services.
Intra-group services	Important service arrangements, principal service providers and pricing / cost allocation policies.
Business restructurings	Important restructurings, acquisitions and divestments.
Intangibles	Group strategy for development, ownership and exploitation of intangibles; important IP and relevant entities.
R&D arrangements	Important agreements and policies relating to research and development and intangibles.
Financing	Group financing arrangements, important financing entities and related transfer pricing policies.
Financial information	Annual consolidated financial statements of the international group.
APA / tax rulings	Relevant unilateral APAs and other tax rulings concerning allocation of income among jurisdictions.

Because much of this information is ordinarily available only with the overseas headquarters, Indian subsidiaries should seek the global Master File, organisational chart, global revenue data, IP information and CbCR details sufficiently in advance.

9. What is the due date for Form 3CEAA for AY 2026-27?

Rule 10DA links the Form 3CEAA filing date to the due date for furnishing the return of income under section 139(1).

Therefore, the due date should be determined according to the return-filing category applicable to the particular constituent entity.

For a taxpayer required to furnish a transfer pricing report under section 92E, the section 139(1) return due date for AY 2026-27 is 30 November 2026. Accordingly, in a normal section 92E case:

Form 3CEAA due date: 30 November 2026

Where section 92E is not applicable but Part A of Form 3CEAA is otherwise required, the relevant section 139(1) return due date applicable to that taxpayer should be separately determined rather than automatically assuming 30 November.

10. What is Form 3CEAB?

Where an international group has more than one constituent entity in India that would otherwise be required to furnish Form 3CEAA, the group can designate one Indian constituent entity to furnish the Master File on behalf of the relevant Indian constituent entities.

This designation is communicated through Form 3CEAB.

The intimation is required 30 days before the due date for furnishing Form 3CEAA.

Accordingly, where the relevant Form 3CEAA due date is 30 November 2026:

Form 3CEAB due date: 31 October 2026

Groups having two or more Indian subsidiaries should review this requirement early. If a common filing is intended, waiting until the end of November would be too late for the 3CEAB intimation.

11. Master File decision tree for an Indian constituent entity

Question	If yes	If no
Is the Indian entity a constituent entity of an international group?	Evaluate Form 3CEAA.	Master File provisions generally do not arise merely from this framework.
Is Part A required?	Yes, for a constituent entity, even if Part B thresholds are not crossed.	Not applicable only if the entity itself is outside the scope of the constituent-entity requirement.
Does consolidated group revenue exceed ₹500 crore?	Proceed to transaction threshold.	Part B ordinarily not triggered.
Do aggregate international transactions exceed ₹50 crore?	Part B applicable.	Check intangible threshold.
Do qualifying intangible transactions exceed ₹10 crore?	Part B applicable.	Part B ordinarily not triggered.
Are multiple Indian constituent entities filing a common Master File?	Evaluate Form 3CEAB at least 30 days before 3CEAA.	Each entity should comply as applicable.

12. What is Country-by-Country Reporting?

Country-by-Country Reporting, commonly referred to as CbCR, is a separate large-group reporting framework. Its objective is to provide tax authorities with a jurisdiction-wise overview of the economic and tax footprint of a multinational group.

CbCR generally contains information regarding each tax jurisdiction in which the group operates, including:

• related-party and unrelated-party revenue;
• profit or loss before income tax;
• income tax paid;
• income tax accrued;
• stated capital;
• accumulated earnings;
• number of employees;
• tangible assets other than cash and cash equivalents;
• constituent entities located in each jurisdiction; and
• the principal business activities of those entities.

CbCR is therefore different from a transaction-by-transaction benchmarking study. It is a high-level risk assessment tool showing where a multinational group reports its revenue, profits, taxes, people and assets.

13. What is the CbCR threshold in India?

The Indian threshold for application of the CbCR provisions is based on the total consolidated group revenue of the international group for the accounting year preceding the relevant reporting accounting year.

The prescribed threshold is:

₹6,400 crore

If the total consolidated group revenue does not exceed the prescribed threshold, the CbCR provisions of section 286 do not apply for that accounting year.

This is important because the CbCR revenue test uses the preceding accounting year, which differs from the Master File threshold mechanics.

14. Example: which revenue year is tested for CbCR?

Assume a foreign-parented international group follows the calendar year and the relevant reporting accounting year is:

1 January 2025 to 31 December 2025

The CbCR threshold is generally tested using the consolidated group revenue for the immediately preceding accounting year:

1 January 2024 to 31 December 2024

If the consolidated revenue for that preceding accounting year exceeds ₹6,400 crore, the CbCR requirements should be evaluated for the reporting accounting year ending 31 December 2025.

Where the consolidated financial statements are prepared in a foreign currency, the prescribed foreign-currency conversion rule should be applied using the relevant telegraphic transfer buying rate.

15. Who actually files the CbCR?

The filing responsibility depends on the location of the parent entity and the CbCR reporting structure of the multinational group.

A. Ultimate parent entity resident in India

Where the parent entity of a qualifying international group is resident in India, the Indian parent entity ordinarily files the CbCR in Form 3CEAD for the relevant reporting accounting year.

An alternate reporting entity resident in India may also be the reporting entity where the applicable conditions are satisfied.

B. Ultimate parent entity outside India

For an Indian subsidiary of a foreign multinational group, the normal global structure is that the parent entity or an alternate reporting entity files the CbCR in its home jurisdiction.

The Indian constituent entity may then have a Form 3CEAC notification requirement, provided the CbCR provisions apply to the international group.

However, an Indian constituent entity can itself become liable to furnish Form 3CEAD in specified circumstances, such as where the overseas parent jurisdiction does not require the relevant CbCR, the prescribed exchange arrangement with India is absent, or there is a systemic failure that triggers local filing under section 286.

16. What is Form 3CEAC?

Form 3CEAC is the Indian CbCR notification form relevant to an Indian resident constituent entity of an international group whose parent entity is not resident in India, where the CbCR provisions apply.

Through the notification, the Indian entity communicates whether it is the alternate reporting entity or provides the details of the parent entity / alternate reporting entity and the jurisdiction in which that reporting entity is resident.

The prescribed time limit is:

At least two months before the due date for furnishing the CbCR.

Because Form 3CEAD is normally due within twelve months from the end of the reporting accounting year, the 3CEAC notification generally falls due around ten months from that year-end.

17. Why 31 October 2026 is critical for many foreign-parented groups

A large number of European, US and other international groups follow a calendar-year reporting period ending 31 December.

Assume the relevant reporting accounting year ended on:

31 December 2025

The normal CbCR due date would be twelve months later:

Form 3CEAD: 31 December 2026

The related Form 3CEAC notification is due two months earlier:

Form 3CEAC: 31 October 2026

Therefore, for an Indian subsidiary of a qualifying calendar-year multinational group, 31 October 2026 can be a double-alert date: Form 3CEB may be due for AY 2026-27 and Form 3CEAC may separately be due for the group’s reporting year ended 31 December 2025.

18. CbCR due-date examples by parent reporting year

Parent / group reporting year-end	CbCR — Form 3CEAD	Notification — Form 3CEAC
31 December 2025	31 December 2026	31 October 2026
31 March 2026	31 March 2027	31 January 2027
30 June 2026	30 June 2027	30 April 2027

These examples illustrate why CbCR cannot be managed only through the Indian statutory financial year calendar.

19. When can an Indian subsidiary itself be required to file Form 3CEAD?

An Indian resident constituent entity other than an Indian parent / alternate reporting entity may have a local CbCR filing obligation in the circumstances prescribed under section 286. Broadly, local filing can arise where the parent is resident in a jurisdiction:

• where the parent is not obligated to furnish a CbCR of the relevant nature;
• with which India does not have the required agreement for exchange of the CbCR; or
• in respect of which a systemic failure has been communicated in accordance with the law.

The detailed conditions, including the availability of an alternate reporting entity mechanism, should be reviewed before concluding that an Indian entity must duplicate the overseas report.

20. What is Form 3CEAE?

Form 3CEAE is relevant where more than one Indian constituent entity could otherwise be required to furnish the CbCR locally under the applicable section 286 provisions.

The international group may designate one Indian constituent entity for the filing, and the designation is communicated through Form 3CEAE.

Do not confuse Form 3CEAE with Form 3CEAB:

Form	Purpose
3CEAB	Designation / intimation for a common Master File — Form 3CEAA filing.
3CEAE	Designation relating to specified local CbCR — Form 3CEAD filing situations.

21. Master File versus CbCR — do not mix the two tests

Particular	Master File	CbCR
Main filing	Form 3CEAA	Form 3CEAD
Related notification / designation	Form 3CEAB	Forms 3CEAC / 3CEAE, depending on the situation
Main provision	Section 92D / Rule 10DA	Section 286 / Rule 10DB
Group revenue threshold	> ₹500 crore for detailed Part B, together with transaction threshold	> ₹6,400 crore, tested with reference to preceding accounting year revenue
Transaction threshold	> ₹50 crore aggregate international transactions OR > ₹10 crore specified intangible transactions	No separate transaction-value threshold
Part A below detailed threshold	Yes, for a constituent entity	Not structured as Part A / Part B
Primary focus	Global business and TP structure	Jurisdiction-wise economic and tax allocation
Deadline basis	Applicable section 139(1) ITR due date	Reporting accounting year-end

22. Where does Form 3CEB fit into the framework?

Form 3CEB is the accountant’s report required under section 92E for a person entering into an international transaction or specified domestic transaction covered by that provision.

For AY 2026-27, where the income-tax return is due on 30 November 2026, Form 3CEB must be furnished one month earlier:

Form 3CEB due date: 31 October 2026

ITR due date in a section 92E case: 30 November 2026

Accordingly, the following separate compliance tracks should be monitored:

• transaction reporting in Form 3CEB;
• Local File / TP documentation under section 92D and Rule 10D;
• Master File under Form 3CEAA;
• Form 3CEAB, if one Indian entity will file the Master File for multiple Indian constituent entities;
• CbCR notification in Form 3CEAC, where applicable;
• CbCR filing in Form 3CEAD, where applicable; and
• Form 3CEAE in specified multi-entity local filing situations.

For Chartered Accountants and tax teams: assureTP by assureOffice is designed to provide a structured workflow for preparing and reviewing Form 3CEB and transfer pricing compliance. The objective is to make transaction capture, review and final filing preparation more systematic while keeping professional review at the centre of the process.

23. What about the Local File / Indian transfer pricing study?

The Indian Local File or transfer pricing documentation is governed principally by section 92D and Rule 10D.

It ordinarily covers matters such as:

• ownership structure and profile of the Indian entity;
• associated enterprises;
• nature and terms of international transactions;
• functions performed, assets employed and risks assumed;
• industry and business analysis;
• selection of the most appropriate method;
• search process and comparable companies / transactions;
• adjustments, where applicable;
• arm’s length price computation; and
• supporting agreements, invoices, financial data and other records.

The monetary threshold under Rule 10D for detailed documentation should be separately considered. Even where detailed prescribed documentation is not mandatory because the transaction value is within the specified limit, the taxpayer must still be able to support the arm’s length nature of the international transactions.

24. Practical annual TP compliance map for an Indian subsidiary

Step	Question to answer	Evidence / action
1	What international transactions occurred during FY 2025-26?	Ledger review, related-party register, agreements, invoices, Form 26AS/AIS where relevant, inter-company confirmations.
2	Is Form 3CEB applicable?	Identify transactions covered by section 92E and prepare accountant’s report.
3	Is detailed Local File documentation required?	Apply section 92D / Rule 10D and preserve benchmarking support.
4	Is the entity a constituent entity of an international group?	Obtain group chart and consolidation status.
5	Is Form 3CEAA Part A required?	Evaluate constituent-entity status independently of Part B thresholds.
6	Does group revenue exceed ₹500 crore?	Obtain group consolidated financial statements.
7	Do ₹50 crore / ₹10 crore transaction thresholds trigger Part B?	Reconcile books and Form 3CEB transaction values.
8	Are there multiple Indian group entities?	Decide whether Form 3CEAB common-filing route is appropriate.
9	Does preceding-year group revenue exceed ₹6,400 crore?	Evaluate CbCR threshold separately.
10	What is the parent entity’s reporting year-end?	Determine exact CbCR / 3CEAC calendar.
11	Who is the CbCR reporting entity?	Obtain parent / alternate reporting entity name, tax residence and filing jurisdiction.
12	Does an Indian local Form 3CEAD obligation arise?	Review exchange arrangement, overseas filing requirement and systemic-failure position.

25. Information Indian subsidiaries should obtain from overseas headquarters

For multinational subsidiaries, the biggest practical difficulty is often not the form itself but obtaining complete group-level information before the deadline.

Indian tax and finance teams should consider requesting the following:

• ultimate parent entity name and jurisdiction;
• group legal and ownership chart;
• list of constituent entities operating in India;
• international group accounting year / reporting year;
• consolidated group revenue for the relevant Master File year;
• consolidated group revenue for the preceding year for the CbCR threshold;
• global Master File;
• annual consolidated financial statements;
• global TP policies;
• details of material intra-group services;
• important intangible assets and IP owners;
• group financing structure;
• relevant APAs and tax rulings;
• CbCR reporting entity name and jurisdiction;
• confirmation that the overseas CbCR will be filed; and
• the exact reporting accounting year covered by that CbCR.

Obtaining only a copy of the overseas Master File may not be sufficient. The Indian forms and local transaction values must still be checked independently.

26. Common compliance mistakes

Common mistake	Why it creates risk
Assuming Form 3CEAA is not required because transactions are below ₹50 crore	Part A may still be required even when Part B is not.
Testing ₹500 crore against Indian-company turnover	The test refers to consolidated revenue of the international group.
Using ₹6,400 crore as a Master File threshold	₹6,400 crore relates to CbCR, not detailed Master File Part B.
Using ₹500 crore as the CbCR threshold	Master File and CbCR have separate tests.
Assuming all transfer pricing compliances are due on 31 October	3CEB, 3CEAA and CbCR-related forms follow different timelines.
Ignoring the foreign parent’s reporting year	CbCR deadlines may follow 31 December, 30 June or another group year-end.
Assuming overseas CbCR filing eliminates all Indian obligations	Form 3CEAC notification may still be required.
Waiting for November to decide common Master File filing	Form 3CEAB may already be due 30 days before 3CEAA.
Copying global Master File values without Indian reconciliation	Inconsistency with Form 3CEB / books can create questions.
Using group revenue for the wrong year for CbCR	CbCR threshold refers to consolidated group revenue of the preceding accounting year.

27. Penalties for non-compliance

Transfer pricing and international-group reporting defaults can attract significant penalties. The exact penalty position should be evaluated with the facts and the statutory provision applicable to the particular failure.

Master File — Form 3CEAA

Failure to furnish information and documents required under section 92D(4), including applicable Master File information, can attract a penalty of:

₹5,00,000 under section 271AA(2).

Form 3CEB

Failure to furnish the accountant’s report required under section 92E can attract:

₹1,00,000 under section 271BA.

Transfer pricing documentation

Failure to furnish information or documents required under section 92D(3) can attract:

2% of the value of the relevant international transaction or specified domestic transaction for each such failure, subject to the applicable statutory conditions.

CbCR

Default	Indicative penalty under section 271GB
Failure to furnish CbCR, where delay does not exceed one month	₹5,000 per day.
Failure continuing beyond one month	₹15,000 per day for the continuing period beyond one month.
Continuing failure after service of penalty order	₹50,000 per day from the specified point.
Specified inaccurate reporting / failure to correct inaccuracy	₹5,00,000.

The penalty framework reinforces the need to separately track Master File, CbCR, notification and Form 3CEB obligations rather than treating “transfer pricing filing” as a single event.

28. Detailed examples

Example 1 — Indian subsidiary of a medium-sized foreign group

International group revenue: ₹420 crore.
Indian subsidiary international transactions: ₹80 crore.
Parent entity: Germany.
Group year-end: 31 December.

Master File: The ₹500 crore group-revenue threshold for detailed Part B is not crossed. Part B would ordinarily not apply on these facts. However, the Indian constituent entity should still evaluate and furnish Part A of Form 3CEAA.

CbCR: If the relevant preceding-year consolidated group revenue is also below ₹6,400 crore, section 286 CbCR provisions would not apply for that accounting year.

Example 2 — ₹700 crore group with ₹60 crore international transactions

Group revenue: ₹700 crore.
Indian international transactions: ₹60 crore.

Both the ₹500 crore revenue threshold and ₹50 crore transaction threshold are crossed. Form 3CEAA Part B applies, in addition to Part A.

Example 3 — intangible threshold triggers Part B

Group revenue: ₹900 crore.
Total international transactions: ₹25 crore.
Qualifying intangible-related international transactions: ₹12 crore.

Although total transactions do not exceed ₹50 crore, the separate ₹10 crore intangible threshold is crossed. Accordingly, detailed Part B applies.

Example 4 — calendar-year foreign parent above CbCR threshold

Parent year-end: 31 December 2025.
Preceding-year consolidated group revenue: ₹8,500 crore.
Ultimate parent: France.
CbCR to be filed by French parent.

The Indian constituent entity should evaluate its Form 3CEAC notification obligation. The normal CbCR due date for the reporting year ending 31 December 2025 is 31 December 2026, making the corresponding Indian notification date 31 October 2026.

Example 5 — March year-end parent

Parent / group reporting year-end: 31 March 2026.
CbCR threshold crossed.

The normal CbCR due date is 31 March 2027, and the corresponding Form 3CEAC notification date is ordinarily 31 January 2027.

This example demonstrates why an Indian company should not assume that all CbCR notifications fall in October.

29. Frequently Asked Questions

1. Our international transactions are below ₹50 crore. Is Form 3CEAA still required?

Potentially yes. The ₹50 crore threshold is relevant to detailed Part B together with the ₹500 crore group-revenue condition. Part A is required for a constituent entity even where the Part B thresholds are not satisfied.

2. Our international group revenue is below ₹500 crore. Do we have any Master File filing?

Detailed Part B would ordinarily not be triggered on the revenue threshold. However, Part A of Form 3CEAA should still be evaluated for the Indian constituent entity.

3. Is the ₹500 crore threshold based on the Indian subsidiary’s turnover?

No. The test refers to the consolidated group revenue of the international group, not merely the Indian entity’s turnover.

4. Our group revenue is ₹650 crore but international transactions are ₹40 crore. Is Part B applicable?

Not merely on those facts, assuming qualifying intangible transactions also do not exceed ₹10 crore. Both the group-revenue condition and at least one transaction-value condition must be met.

5. Our group revenue is ₹650 crore and international transactions are ₹55 crore. Is Part B applicable?

Yes. The consolidated group revenue exceeds ₹500 crore and aggregate international transactions exceed ₹50 crore.

6. Total international transactions are ₹20 crore but royalty / intangible transactions are ₹11 crore. Is Part B applicable?

Yes, assuming the consolidated group revenue exceeds ₹500 crore. The separate ₹10 crore threshold for the specified intangible-property transactions is crossed.

7. Is the global Master File prepared by our parent enough?

The global Master File may provide much of the information needed for Part B, but the Indian entity must still comply with the prescribed Indian filing. Local data, entity details and transaction values should be reconciled before filing.

8. What is the Form 3CEAA due date for AY 2026-27?

Form 3CEAA is due on or before the applicable section 139(1) return due date. In a normal section 92E transfer-pricing case for AY 2026-27, this is 30 November 2026.

9. Is 30 November 2026 automatically the 3CEAA due date for every constituent entity?

No. The rule links 3CEAA to the applicable section 139(1) return due date. The 30 November date applies where the taxpayer falls within the transfer-pricing return-filing timeline. Other cases should use the section 139(1) due date applicable to that taxpayer.

10. What is Form 3CEAB?

Form 3CEAB is the intimation used where one Indian constituent entity is designated to furnish Form 3CEAA for multiple Indian constituent entities of the international group.

11. When is Form 3CEAB due?

It is required 30 days before the due date for Form 3CEAA. Therefore, where Form 3CEAA is due on 30 November 2026, Form 3CEAB is ordinarily due by 31 October 2026.

12. What is the Indian CbCR threshold?

The prescribed consolidated group revenue threshold is ₹6,400 crore, tested with reference to the preceding accounting year as required by section 286.

13. Is the ₹6,400 crore threshold tested using the Indian company’s turnover?

No. It refers to total consolidated group revenue of the international group for the relevant preceding accounting year.

14. Is the Indian threshold simply EUR 750 million?

For Indian statutory compliance, the prescribed rupee threshold is ₹6,400 crore. Where group financial statements are in foreign currency, the prescribed conversion mechanism should be applied.

15. Our foreign parent files CbCR outside India. Does the Indian subsidiary also file Form 3CEAD?

Not ordinarily where the overseas reporting structure and exchange conditions satisfy the Indian provisions. However, the Indian entity may still have a Form 3CEAC notification obligation. Local Form 3CEAD filing can arise in the specific circumstances prescribed under section 286.

16. What is Form 3CEAC?

Form 3CEAC is the notification through which an Indian resident constituent entity of a foreign-parented qualifying international group reports the relevant parent / alternate reporting entity information to the Indian tax authority.

17. When is Form 3CEAC due?

It is due at least two months before the due date for furnishing the CbCR.

18. Our German parent follows January-December. What is the upcoming 3CEAC date?

If the relevant reporting accounting year ended on 31 December 2025 and the CbCR provisions apply, the normal CbCR due date is 31 December 2026 and the corresponding Form 3CEAC date is 31 October 2026.

19. Our foreign parent follows a 31 March year-end. What dates should we monitor?

For a reporting accounting year ending 31 March 2026, the normal Form 3CEAD date is 31 March 2027 and the related Form 3CEAC date is ordinarily 31 January 2027.

20. Does CbCR follow the Indian subsidiary’s April-March financial year?

Not necessarily. For a foreign-parented group, the relevant accounting year is linked to the annual accounting period for which the foreign parent prepares its financial statements under its applicable law or accounting standards.

21. What is Form 3CEAE?

Form 3CEAE relates to designation of an Indian constituent entity in specified local CbCR filing situations involving multiple Indian constituent entities. It is not the Master File designation form.

22. What is the difference between Form 3CEAB and Form 3CEAE?

3CEAB relates to a common Master File / 3CEAA filing. 3CEAE relates to designation for specified local CbCR filing situations.

23. Is Form 3CEB the same as the Master File?

No. Form 3CEB is the accountant’s report on international / specified domestic transactions. The Master File is Form 3CEAA and provides group-level information.

24. What is the Form 3CEB due date for AY 2026-27?

For a transfer-pricing case where the section 139(1) ITR due date is 30 November 2026, Form 3CEB is due by 31 October 2026.

25. Can we file Form 3CEB and ignore the TP study if benchmarking is available later?

No. Form 3CEB reporting and the underlying arm’s length analysis are interconnected. The taxpayer should maintain the required documentation and support for the positions reported in the accountant’s report.

26. Are Master File and CbCR required only for companies?

The provisions are framed around a person being a constituent entity of an international group and the relevant statutory definitions, rather than simply using the label “company”. Applicability should therefore be tested from the statutory status and group structure.

27. If the group has two Indian companies, do both have to separately file Part B?

The group may use the designated-entity mechanism under Rule 10DA where its conditions are satisfied. Form 3CEAB should be filed within the prescribed timeline before the common Form 3CEAA filing.

28. What if the overseas parent year-end is different from the Indian entity’s year-end?

This is common. The Master File and CbCR provisions contain their own accounting-year concepts. Particularly for CbCR, the foreign parent’s annual reporting period can drive the notification and filing calendar.

29. What happens if the ₹6,400 crore CbCR threshold is not crossed?

Section 286 provides that its CbCR provisions do not apply to an international group for an accounting year where the consolidated group revenue for the preceding accounting year does not exceed the prescribed amount.

30. What should an Indian subsidiary do first if it is unsure whether Master File or CbCR applies?

Obtain four facts immediately: (1) group consolidated revenue, (2) international transaction values, (3) parent entity jurisdiction and reporting year-end, and (4) preceding-year consolidated group revenue for CbCR. These facts usually resolve most of the applicability analysis.

30. Recommended action before 31 October 2026

For Indian entities having international transactions or belonging to multinational groups, the following should be completed well before the deadline:

1. Freeze the list and values of FY 2025-26 international transactions.
2. Complete the Form 3CEB data and reconcile it to books and financial statements.
3. Complete or update the Local File / benchmarking analysis.
4. Identify all Indian constituent entities of the international group.
5. Obtain consolidated group revenue for the Master File threshold.
6. Evaluate Form 3CEAA Part A and Part B separately.
7. Decide whether a common Form 3CEAA filing will be used and, if so, file Form 3CEAB on time.
8. Obtain the parent entity’s reporting year-end and prior-year consolidated group revenue.
9. Evaluate whether the ₹6,400 crore CbCR threshold is crossed.
10. Confirm the CbCR reporting entity and jurisdiction.
11. For calendar-year foreign-parented groups, specifically review whether Form 3CEAC is due on 31 October 2026.
12. Reconcile all narratives and amounts across Form 3CEB, Local File, Master File, CbCR and financial statements.

31. Use technology to make Form 3CEB preparation more structured

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32. Key takeaway

For AY 2026-27, Indian entities should not treat transfer pricing as a single 31 October filing exercise.

The practical sequence is:

Form 3CEB → Local File → Form 3CEAA Part A / Part B → Form 3CEAB where applicable → CbCR threshold → Form 3CEAC notification → Form 3CEAD / 3CEAE where applicable.

For many Indian subsidiaries of foreign groups following a 31 December year-end, 31 October 2026 is particularly important because it can be both the Form 3CEB deadline for AY 2026-27 and the Form 3CEAC notification date for the reporting accounting year ended 31 December 2025.

The best way to avoid last-minute issues is to obtain group-level information from the foreign headquarters early, determine the parent reporting year, test the Master File and CbCR thresholds independently, and reconcile every filing with the Indian books and transfer pricing documentation.

Professional disclaimer: This article is intended for general educational and client-information purposes. It is based on the law and compliance position reviewed up to 24 September 2026 for FY 2025-26 / AY 2026-27. Applicability depends on the facts, group structure, reporting year, jurisdiction and subsequent notifications, circulars, extensions or judicial developments. Specific professional advice should be obtained before taking a filing position.