Form 3CEB

What is Form 3CEB?

Form 3CEB is a mandatory tax form that companies must file when engaging in international or specified domestic transactions with associated enterprises. The form is prescribed under Section 92E of the Income Tax Act, 1961, and serves as a detailed transfer pricing report.

The primary purpose of Form 3CEB is to ensure that cross-border and specified domestic transactions are conducted at arm’s length prices, preventing tax avoidance through profit shifting or manipulation of transaction values.
 

Key Highlights of Form 3CEB:

• Mandatory for companies engaged in international and specified domestic transactions.
• Filed along with Form 3CD for tax audit compliance.
• Must be certified by a Chartered Accountant (CA).
• Helps prevent transfer pricing manipulation and ensures fair taxation.
   

Why is Form 3CEB Important?

The concept of transfer pricing exists to ensure that related parties do not manipulate pricing to shift profits to jurisdictions with lower tax rates. This prevents profit erosion and tax avoidance.

By filing Form 3CEB, businesses provide the Indian tax authorities with a clear record of their cross-border and specified domestic transactions, ensuring that:

• Taxable profits are fairly allocated across different jurisdictions.
• The Indian government receives its due share of tax revenues.
• Transfer pricing laws are enforced effectively, preventing tax evasion.
   

Who Needs to File Form 3CEB?

Form 3CEB applies to businesses that engage in international transactions or specified domestic transactions with related parties.

International Transactions

An international transaction refers to any transaction between two or more associated enterprises, where at least one entity is a non-resident. These transactions include:

• Purchase, sale, or lease of tangible or intangible assets.
• Provision of services, including technical services and consulting.
• Borrowing or lending of money.
• Allocation of expenses or cost-sharing arrangements.
• Transactions affecting profits, losses, or income of enterprises.

Specified Domestic Transactions

A specified domestic transaction (SDT) is a transaction between two associated entities within India, which exceeds ₹20 crore in a financial year. These include:

• Expenditures made to related parties covered under Section 40A(2)(b).
• Transactions between businesses eligible for profit-linked deductions under Section 80-IA.
• Transfer of goods or services within group entities.

For international transactions, Form 3CEB is mandatory, regardless of transaction value. However, for domestic transactions, filing is required only if the value exceeds ₹20 crore.
 

Due Date for Filing Form 3CEB

orm 3CEB must be filed on or before 31st October following the financial year in which the transaction took place.

📌 For Assessment Year 2025-26, the deadline is 31st October 2025.

Filing after the due date may attract penalties under the Income Tax Act, making timely compliance crucial for businesses.
 

How to File Form 3CEB Online?

Filing Form 3CEB is a structured process that requires the involvement of a Chartered Accountant (CA). Below is a step-by-step guide to filing Form 3CEB online:

Step 1: Appoint a Chartered Accountant (CA)

The taxpayer must appoint a licensed CA to audit the transactions.
The CA will be responsible for preparing and verifying the form.

Step 2: Assign the Form to CA via e-Filing Portal

Log in to the Income Tax e-Filing portal.
Navigate to ‘Authorised Partners’ → ‘My Chartered Accountants’.
Assign Form 3CEB to the selected CA by choosing the relevant assessment year and filing type.

Step 3: CA Completes the Form

The CA accepts the request and prepares Form 3CEB after reviewing all relevant transaction details.
The form includes:
Details of international transactions (Part B).
Details of specified domestic transactions (Part C).

Step 4: Taxpayer Reviews the Form

Once submitted by the CA, the taxpayer must review the form in the e-Filing portal.
If satisfied, the taxpayer approves and submits the form for final filing.

Step 5: Submission to the Income Tax Department

Upon approval, Form 3CEB is filed with the Income Tax Department electronically.
The taxpayer receives an acknowledgment confirming successful filing.
 

Structure of Form 3CEB

Form 3CEB consists of three parts, each covering different aspects of transfer pricing transactions:

Part A: General Information

Basic details of the taxpayer and associated enterprises.
PAN, business name, and address of the entities involved.

Part B: Details of International Transactions

Nature and value of international transactions.
Details of associated enterprises.
Transactions related to tangible and intangible assets, financing, services, and guarantees.

Part C: Specified Domestic Transactions

Description and value of transactions with related domestic parties.
Transactions related to profit-linked deductions and inter-company dealings.

Each section must be detailed and accurate, as any inconsistencies may lead to penalties and legal scrutiny.

Consequences of Non-Compliance

Failure to comply with Form 3CEB filing requirements can result in significant penalties under Section 271BA of the Income Tax Act:

Late Filing Penalty

₹1,00,000 for not filing Form 3CEB within the due date.

Incorrect or Incomplete Filing

The Income Tax Department may reject incorrect forms and impose additional penalties.

Audit and Scrutiny

Improper documentation can lead to transfer pricing audits, delaying tax assessments.

Timely and accurate filing of Form 3CEB helps businesses avoid penalties and ensures tax compliance.

Conclusion

Form 3CEB plays a critical role in transfer pricing compliance, ensuring that cross-border and specified domestic transactions adhere to fair market principles. By accurately reporting intercompany transactions, businesses can avoid tax disputes, penalties, and audits.

Whether dealing with international trade, intra-group services, or domestic related-party transactions, companies must file Form 3CEB within the due date to remain compliant with Indian tax laws.

Engaging a competent Chartered Accountant and maintaining proper transfer pricing documentation is essential for smooth tax assessments and regulatory compliance.