At a glance
#Dates are for an example year end of Mar 31, 2026. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Income Tax Department, Central Board of Direct Taxes (CBDT). Summaries are simplified; check the linked official source before relying on them.
The law
#For the year ended 31 March 2026 (assessment year 2026-27) the Income-tax Act, 1961 still applies: ss. 92 to 92F (arm's length price, documentation, accountant's report), s. 286 (CbC) and Income-tax Rules 10A to 10E, 10DA and 10DB. The new Income-tax Act, 2025 (TP in ss. 161 to 174, CbC in s. 511) applies from tax year 2026-27, so it first matters for years ending 31 March 2027. India is not bound by the OECD Guidelines; the statute and rules govern, though Rules 10DA/10DB follow BEPS Action 13.
Documentation
#Local documentation (Rule 10D) for every person with international transactions or specified domestic transactions; full Rule 10D documentation is not required if aggregate international transactions are INR 1 crore or less. It must exist by the 'specified date' (31 October) and be produced within 10 days of a notice, extendable by up to 30 days (s. 92D(3), as amended in 2023). Master File (Form 3CEAA): Part A by every constituent entity of an international group; Part B if group consolidated revenue exceeds INR 500 crore AND international transactions exceed INR 50 crore (or intangible transactions exceed INR 10 crore). Due with the return of income (30 November). Records kept 8 years. Documents in English in practice.
Methods
#Six methods: CUP, resale price, cost plus, profit split, TNMM and 'other method' (s. 92C, Rule 10B). Most appropriate method rule. Range concept (Rule 10CA): with 6 or more comparables under CUP, RPM, CPM or TNMM, the arm's length range is the 35th to 65th percentile; if the tested price is outside, adjust to the median. With fewer than 6, use the arithmetic mean with a tolerance (3%, or 1% for wholesale traders). Multiple year data allowed.
Penalties
#s. 271AA: 2% of the value of each international transaction for failing to keep documents, failing to report a transaction or keeping wrong information; INR 5 lakh for not furnishing the master file. s. 271G: 2% of the transaction value for failing to produce documents on request. s. 271BA: INR 1 lakh for not filing Form 3CEB. s. 271GB (CbC): INR 5,000 per day up to one month, INR 15,000 per day after that, higher after a penalty order, and INR 5 lakh for inaccurate information. Under-reporting from TP adjustments can attract s. 270A penalties (misreporting at 200%). Reasonable cause relief under s. 273B.
Pillar Two
#India has not enacted Pillar Two: there is no IIR, UTPR or QDMTT and no Indian GloBE filing. It is not listed on the OECD central record of qualified rules (current to 1 May 2026). Indian entities of in-scope groups may still be covered by top-up taxes and GIRs filed in other countries.
Other rules
#APAs (unilateral, bilateral, multilateral) under s. 92CC with rollback for up to 4 prior years. Safe harbour rules (Rules 10TA to 10TG). Secondary adjustment (s. 92CE) where a primary adjustment exceeds INR 1 crore and the excess money is not repatriated within the prescribed time. Interest limitation (s. 94B): interest paid to non-resident associated enterprises above INR 1 crore is capped at 30% of EBITDA. Finance Act 2026 (s. 5) replaced Explanation 2 to s. 139(1) with a table: TP cases 30 November, other companies and audit cases 31 October. CBDT press release of 28 September 2026 extended only the audit-case date (Sl. No. 2) to 21 November 2026; TP cases stay at 30 November and Form 3CEB at 31 October. India's previous year always ends 31 March, so dates below are 'fixed' with yearOffset 0 (FYE 31 March 2026 gives 31 October 2026 and 30 November 2026). Under the 2025 Act the forms are renumbered (for example Master File becomes Form 56, CbC forms 57 to 60).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Form 3CEB accountant's report Due by the 'specified date', defined in s. 92F(iv) as one month before the s. 139(1) due date (30 November), so 31 October of the assessment year. Signed by a chartered accountant. The 28 September 2026 CBDT extension does not cover TP cases. | Fixed calendar date (e.g. Oct 31, 2026) (a Saturday: may move to the next working day) | Every person with an international transaction (no minimum) or a specified domestic transaction. | Income-tax Act, 1961, s. 92F(iv) definition of specified date |
| 2 | Rule 10D TP documentation (local file) Not filed. Must exist by the specified date (31 October). Must be produced within 10 days of a notice from the Assessing Officer or Commissioner (Appeals), extendable by up to 30 more days (s. 92D(3), amended by Finance Act 2023). Keep for 8 years from the end of the assessment year. | Fixed calendar date (e.g. Oct 31, 2026) (a Saturday: may move to the next working day) | Full documentation needed if aggregate international transactions exceed INR 1 crore (INR 10 million). Below that, keep enough evidence to support the price. | Income-tax Act, 1961, s. 92D (2025 version) |
| 3 | Form 3CEAB designation of entity to file master file At least 30 days before the Form 3CEAA due date (Rule 10DA(5)). With a 30 November due date this is 31 October. | Fixed calendar date (e.g. Oct 31, 2026) (a Saturday: may move to the next working day) | Only where a group has more than one constituent entity in India and designates one to file Form 3CEAA. | Notification 92/2017, Rule 10DA(4)-(5) |
| 4 | Income-tax return (ITR-6) for companies with TP reporting Due date = 30 November of the assessment year for assessees required to furnish a s. 92E report (Finance Act 2026, s. 5, table Sl. No. 1). For FYE 31 March 2026 this is 30 November 2026. The CBDT extension to 21 November 2026 covers only non-TP audit cases (Sl. No. 2), so it does not move this date. | Fixed calendar date (e.g. Nov 30, 2026) | All companies. The 30 November date applies where s. 92E (Form 3CEB) applies; other companies and audit cases file by 31 October. | Finance Act, 2026, s. 5 (substituted Explanation 2 to s. 139(1)) |
| 5 | Form 3CEAA master file (Parts A and B) Due on or before the s. 139(1) due date (Rule 10DA(2)), which for TP cases is 30 November. Filed with the DGIT (Risk Assessment). | Fixed calendar date (e.g. Nov 30, 2026) | Part A: every constituent entity of an international group. Part B: group consolidated revenue above INR 500 crore AND international transactions above INR 50 crore (or intangible-related transactions above INR 10 crore). The revenue figure here is group revenue. | Notification 92/2017 inserting Rules 10DA and 10DB (Gazette) |
| 6 | Form 3CEAC CbC intimation At least two months before the CbC report due date (Rule 10DB(2)), i.e. 10 months after the end of the group's reporting accounting year. Count from the group's year end, not the Indian 31 March year end. | 10 months after year end (e.g. Jan 31, 2027) (a Sunday: may move to the next working day) | Indian constituent entities of a group whose parent is not resident in India, where group consolidated revenue in the preceding accounting year is INR 6,400 crore or more. | CBDT brochure: Master File and Country-by-Country Report (March 2026) |
| 7 | Form 3CEAD CbC report Within 12 months from the end of the reporting accounting year (s. 286(2)). Secondary local filing follows the same period; if India notifies a systemic failure, 6 months from the end of the month of that notice. Form 3CEAE is used to designate one Indian entity for local filing. | 12 months after year end (e.g. Mar 31, 2027) | Indian parent or alternate reporting entity of a group with consolidated revenue of INR 6,400 crore or more; also a local entity under s. 286(4) (secondary filing) if the parent jurisdiction does not file or exchange. | Income-tax Act, 1961, s. 286 (2026 version) |