Written by Jayasri P · Last updated 20 August 2026 · Statutory references current to the Income-tax Act 2025 and the Income-tax Rules 2026.
The accountant’s report is due at least one month before the return of income under section 263(1), which places it on 31 October where the return falls on 30 November. The Master File follows the return date, and the Country-by-Country report runs on its own twelve-month clock.
The Form 3CEB due date is one of four separate filing clocks running in a single tax year, and only one of them is tied to the return of income in the way most finance calendars assume, so a compliance timeline built around the November date is already late by the time anyone opens it. The accountant’s report is prepared a month before the return, the Master File runs alongside it, and the Country-by-Country report is timed from a different year end. Each compliance date is ruled by its own provision, so missing one does not put the others at risk, and fulfilling one does not discharge the rest.
What does the transfer pricing calendar look like for a tax year?
Four filings and two intimations, on three separate clocks. The table sets out each filing, the provision it sits under in the Income-tax Act 2025 and the Income-tax Rules 2026, and the date it falls due for a person whose return is due on 30 November.
| Obligation | Statutory anchor | Falls due |
|---|---|---|
| Contemporaneous documentation in place | Section 171 (erstwhile 92D), Rule 84 | Before the accountant’s report is signed |
| Accountant’s report, Form 3CEB, now Form 48 | Section 172 (erstwhile 92E), Rule 85 | 31 October — one month before the return |
| Return of income | Section 263(1) | 30 November |
| Intimation of the designated constituent entity | Rule 123 | Thirty days before the Master File form |
| Master File (the prescribed Master File form) | Rule 123 (erstwhile Rule 10DA) | 30 November — with the return |
| Intimation of the reporting entity for CbC purposes | Rule 124 (erstwhile Rule 10DB) | Two months before the CbC report |
| Country-by-Country report | Section 511 (erstwhile 286), Rule 124 | Twelve months from the end of the reporting accounting year |
All the dates above except for the Country-by-Country pair are attached to the date of the income return, and so this makes the return seem like the only deadline. The return is not the filing that gets missed. One should read the table as three clocks and not as a single list, because the reporting clock, the return clock and the group clock begin from three different events. The two intimations are easy to miss. Neither is a substantive filing, and both fall due before the report they refer to.
When is the Form 3CEB due date?
One month before the due date for the return of income. For a taxpayer engaged in international transactions the return falls due on 30 November, and the report therefore falls due on 31 October.
According to the Central Board of Direct Taxes, Form No. 48, the erstwhile Form 3CEB, must be filed on or before the date one month before the due date for furnishing the return of income under section 263(1) for that tax year. It serves neither as a schedule to the return nor as an annexure that accompanies it. That separation is the single most useful thing to understand about the transfer pricing audit due date, because everything else in the calendar follows from it.
Did renumbering move the due date?
The form has been renumbered, but its timing has not. Steadfast Business Consulting (SBC) has provided some details on the change in a separate note on the transition from Form 3CEB to Form 48. The due date remained unchanged when Form 3CEB changed to Form 48.
Why do teams working backwards from the return deadline miss the report?
Because the deadline for the return is the wrong anchor. A finance department that begins its work from 30 November and reserves the regular lead time of three or four weeks to submit the return has already consumed the month the statute fixed for the report, and by the time the benchmarking file is opened the certification window has closed behind it. The error is structural rather than careless, since the return is the deadline everyone else in the business already works to.
What does the one-month gap actually reserve?
Time for a certification that cannot be compressed. The accountant needs the related-party ledger reconciled, the inter-company agreements assembled and the benchmarking analysis complete before signing, and none of that work can begin in the last week of October if the underlying data has not been pulled from the accounting system.
The gap exists so that the position certified in the report is identical to the position that appears in the return. When the report is compiled at the same time as the return instead of before it, the two documents drift. The difference between the transactions indicated in the report and the figures in the return is the exact discrepancy that a Transfer Pricing Officer will hunt for first.
How should the calendar be read instead?
Forwards, from the end of the tax year. The following steps are listed in the order they have to be performed, where each line depends on the previous one rather than on the return date.
| Step | When it has to be finished |
|---|---|
| Related-party transaction schedule reconciled to the ledger | Within three months of the year end |
| Functional analysis and inter-company agreements reviewed | Before benchmarking begins |
| Benchmarking study and documentation under Rule 84 completed | Ahead of October, not during it |
| Form 48 uploaded, digitally signed and accepted on the portal | 31 October |
| Return of income furnished | 30 November |
Another consequence of working forwards is that it uncovers the dependency responsible for most of the harm: benchmarking cannot begin until the transaction schedule is final.
When is the Master File obligation due?
On or before the due date for submitting the return of income, which places the prescribed Master File form on 30 November with the return rather than a month earlier. The provision governing the Master File submission is Rule 123 of the Income-tax Rules 2026, which has taken the place of Rule 10DA of the 1962 Rules, and because that provision determines the due date by reference to the return, a group that has discharged its October obligation still has another obligation waiting in November.
One earlier date sits in front of it. Where an international group has multiple constituent entities in India and appoints one of them to make the filing, the intimation naming that entity is due thirty days beforehand. In practice, the designation must be settled by the end of October. Groups that leave the designation to the filing week discover that the intimation window has already passed.
When is the Country-by-Country report due?
Within twelve months from the end of the reporting accounting year. The Country-by-Country deadline is the one obligation in the calendar that is not tied to the Indian return at all, because section 511 of the Income-tax Act 2025 measures the period from the end of the reporting accounting year of the international group rather than from any Indian filing date.
This distinction is important for groups whose parent has a December or June year end, since the reporting accounting year is dependent on the parent rather than on the Indian tax year. A calendar-year group therefore runs a December cycle irrelevant to its Indian filing calendar.
Is there an intimation before the CbC report?
A second intimation runs ahead of this one. A constituent entity resident in India must notify the department of the identity and residence of the entity filing the report, and that intimation is due two months prior to the due date for the Country-by-Country report itself, which places it well before the group has finished assembling the report it relates to.
Which tax year do these dates apply to?
Tax year 2026-27 onwards. Both the Income-tax Act 2025 and the Income-tax Rules 2026 have been enforced from 1 April 2026, so the section and rule numbers referenced in this guide are those that apply from that date onwards, and any schedule still built on section 92E and Rule 10E is describing an obligation that has since moved.
Whenever a report relates to any past tax year, the numbering in force for that year continues to apply, hence internally created checklists, engagement letters and audit committee documentation still employ the previous numbering. The dates have remained unchanged; only the numbering changed, and the sequence a finance team has to run through each year is unchanged.
What does a late accountant’s report cost?
A fee of ₹50,000 applies for a delay of up to one month, and ₹1,00,000 thereafter. Not supplying the report from an accountant now results in a fee under section 428(4)(d) of the Income-tax Act 2025 instead of a penalty, which removes the reasonable-cause argument that used to be available, so a missed date simply becomes a cost. The distinction between a fee and a penalty is not a trivial drafting issue, since the fee is applied on the facts alone.
Documentation defaults and information defaults remain penalties, and are set out separately in transfer pricing non-compliance penalties.
Does a specified domestic transaction change the dates?
No. In instances where the overall value of specified domestic transactions goes beyond twenty crore rupees in a single tax year, the accountant’s report has to include them also, and it runs on the same 31 October date as the international transaction filing. This means that a purely domestic group crossing that threshold inherits the whole calendar rather than a lighter version of it.
The reporting calendar is not classified by transaction type. Both sets of transactions are reported in the same accountant’s report and certified on the same date. Which domestic dealings qualify in the first place is a separate question, dealt with in specified domestic transaction compliance.
Who should own the calendar inside the business?
Whoever owns the related-party ledger, working to a schedule set at the start of the year rather than one fixed in the last quarter of it. The return of income under section 263(1) fixes the outer date, and every transfer pricing obligation is then positioned relative to it. Ownership matters more than seniority here, since the person who reconciles the ledger is the one who determines whether the October date is achievable.
SBC was recognised as a Notable Transfer Pricing Firm 2024 by ITR World Tax, and the company offers transfer pricing services consisting of documentation, the accountant’s report, Master File and Country-by-Country filings, along with representation in the assessment process for groups filing in multiple jurisdictions. Where the year end of the group parent company is not the same as the Indian tax year, and the intimations consequently fall in different quarters, the transfer pricing services team works to the forward calendar set out above rather than to the return date.
If you have not opened this year’s benchmarking file yet, October is later than it looks. Ask SBC for a dated compliance schedule built around your group year end.
Frequently Asked Questions
Is the transfer pricing audit due date the same as the return due date?
No. The accountant’s report must be submitted at least one month before the return of income under section 263(1). If the return is due on 30 November, the report is due on 31 October. Treating them as a single deadline is the most common calendar error.
Does the Master File have the same due date as Form 48?
No. The prescribed Master File form is due by 30 November, whereas the accountant’s report is due on the earlier date of 31 October.
What is the deadline for the Country-by-Country report?
Twelve months from the end of the reporting accounting year of the international group, as stated under section 511 of the Income-tax Act 2025 in conjunction with Rule 124. It is not linked to the Indian return date.
Is there any extension available for Form 48?
Only where the Central Board of Direct Taxes extends the underlying return due date, since the report date is defined by reference to the date under section 263(1). No separate mechanism exists for extending the date of the report on its own.
What happens if the return is filed late but the report was filed on time?
The report obligation is satisfied and the fee under section 428(4)(d) does not arise for it. Late filing of the return carries its own consequences, which are assessed separately from the transfer pricing reporting position.
Do the old section numbers still appear on the portal?
Some secondary references and older internal checklists are still in the old numbering. Cite section 172 and Rule 85 for the accountant’s report, section 171 and Rule 84 for the documentation, and section 511 with Rule 124 for Country-by-Country reporting.