# Form 48 (formerly Form 3CEB) Accountant's Report

> Every taxpayer with an international transaction or specified domestic transaction must file an accountant's report certifying the transactions and their arm's length pricing — Form 3CEB under the 1961 Act, renumbered as Form 48 under the Income-tax Act, 2025 from tax year 2026-27. It is due one month before the return due date for transfer pricing cases. Failure to file can attract a penalty of ₹1 lakh, and incorrect reporting further penalties.

Practice: Transfer Pricing — https://www.industax.com/services/transfer-pricing/

The report lists every transaction with associated enterprises by nature, value and method. Mismatches between Form 48, the financial statements and the TP documentation are a common audit trigger.

We reconcile transactions with the books and documentation, and file the report through a chartered accountant on time.

## Key facts

| Item | Detail |
| --- | --- |
| Form | Form 48 (formerly 3CEB) |
| Due | One month before the return due date |
| Applies to | Any international transaction or SDT above ₹20 crore |
| Penalty for not filing | ₹1 lakh |

## Who needs this

- Entities with related-party cross-border transactions
- Groups with specified domestic transactions
- Foreign-owned Indian companies

## What's included

- Transaction reconciliation
- Report preparation and certification
- Filing

## Documents

- Ledger of related-party transactions
- TP documentation
- Financial statements

## Process

1. **Reconcile** — Transactions matched with books.
2. **Certify** — Report prepared and signed.
3. **File** — Uploaded before the deadline.

## FAQs

### Is Form 48 needed if the transaction value is small?

Yes. The report is required for any international transaction with an associated enterprise, regardless of value.

### What is the return due date for transfer pricing cases?

Generally 30 November, with the accountant's report due by 31 October, unless the CBDT extends the dates.

### Can Form 48 be revised?

Revisions are possible within the time allowed, but differences from the original attract scrutiny. Getting it right the first time matters.

## Official sources

- Income Tax e-Filing portal: https://www.incometax.gov.in/

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Canonical page: https://www.industax.com/services/transfer-pricing/form-48-accountant-report
Publisher: Indus Tax — CA-led tax and compliance firm (https://www.industax.com). Contact: info@industax.com, 9059139258.
This is general information, not advice for your specific facts.