# Transfer Pricing Documentation, Benchmarking & APAs

> Transfer pricing rules require transactions between associated enterprises — an Indian company and its foreign parent or subsidiary, for example — to be priced at arm's length. Indian taxpayers with international or specified domestic transactions must keep TP documentation and file an accountant's report (Form 3CEB, renumbered Form 48 under the Income-tax Rules, 2026 from tax year 2026-27).

## Who this is for

- Indian subsidiaries of foreign groups
- Indian companies with overseas subsidiaries, branches or LLPs
- Groups with intra-group services, royalties, loans or guarantees
- Businesses with specified domestic transactions with related parties

## Services

- [Transfer Pricing Study & Documentation](https://www.industax.com/services/transfer-pricing/tp-study-documentation) — Benchmarking and contemporaneous documentation for related-party transactions
- [Form 48 (formerly Form 3CEB) Accountant's Report](https://www.industax.com/services/transfer-pricing/form-48-accountant-report) — Transfer pricing certification filed before the return
- [Master File & Country-by-Country Reporting](https://www.industax.com/services/transfer-pricing/master-file-cbcr) — Group-level TP filings for large multinational groups
- [Advance Pricing Agreement (APA)](https://www.industax.com/services/transfer-pricing/advance-pricing-agreement) — Unilateral and bilateral APAs with rollback
- [Transfer Pricing Safe Harbour](https://www.industax.com/services/transfer-pricing/tp-safe-harbour) — Opting for prescribed margins to avoid TP audits
- [Specified Domestic Transactions (SDT)](https://www.industax.com/services/transfer-pricing/specified-domestic-transactions) — Domestic transfer pricing for large related-party dealings
- [Transfer Pricing Assessment & Disputes](https://www.industax.com/services/transfer-pricing/tp-assessment-dispute) — TPO proceedings, DRP, appeals and MAP

## FAQs

### When is Form 3CEB due?

Form 3CEB is generally due one month before the return due date for transfer-pricing cases — 31 October for most companies with a 30 November return date. From tax year 2026-27 the report is Form 48 under the Income-tax Rules, 2026. Always check the latest CBDT notifications for extensions.

### What is the penalty for not filing Form 3CEB?

₹1 lakh under Section 271BA of the Income-tax Act, 1961, in addition to separate penalties for not maintaining documentation and for adjustments made in assessment.

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This is general information, not advice for your specific facts.