The Classic Partners LLP
Transfer Pricing Audit (Form 3CEB)
Every taxpayer with international transactions or specified domestic transactions must obtain a Chartered Accountant's report in Form 3CEB under Section 92E. We certify and file it — accurately and on time.
Get Your 3CEB FiledWhat is the Transfer Pricing Audit?
The TP audit is the accountant's examination and certification of your related-party transactions. Under Section 92E, a CA reports — in Form 3CEB — every international transaction and specified domestic transaction, the method applied, and whether the pricing meets the arm's length standard set by TP law.
Key Compliance Points
- Who must file: every person who has entered into an international transaction with an AE — there is no materiality threshold for Form 3CEB on international transactions.
- Due date: Form 3CEB is filed electronically by 31 October following the financial year (one month before the TP return due date).
- Backing documentation: the report rests on the Rule 10D file and TP study — certification without them is exposure, not compliance.
- Coverage: goods, services, intangibles, financing, guarantees, reimbursements, and deemed transactions all go into the report.
Penalties for Non-Compliance
- Failure to furnish Form 3CEB: penalty of Rs. 1,00,000 (Section 271BA).
- Failure to maintain or furnish documentation: 2% of the transaction value (Sections 271AA / 271G) — see TP documentation.
- Adjustment risk: unreported or mis-reported transactions invite reference to the TPO and income adjustments with interest and penalty exposure.
Our TP Audit Process
Transaction Mapping
Ledger and agreement review to capture every reportable transaction.
Method & ALP Review
Validation against the benchmarking analysis.
Form 3CEB Preparation
Clause-by-clause drafting with annexure schedules.
CA Certification & E-Filing
Digital signature and portal filing before the due date.
Reconciliation
3CEB tied to the tax audit report, financials, and ITR disclosures.
Assessment Support
Defence of the certified positions in TP assessment.
Frequently Asked Questions
What is Form 3CEB?
Form 3CEB is the Chartered Accountant's report under Section 92E certifying all international transactions and specified domestic transactions with associated enterprises, the methods applied, and the arm's length position.
Who is required to obtain a transfer pricing audit?
Every taxpayer entering into any international transaction with an associated enterprise, regardless of value, and taxpayers whose specified domestic transactions exceed Rs. 20 crore in the year.
What is the due date for Form 3CEB?
31 October following the end of the financial year, filed electronically with the CA's digital signature before the transfer-pricing return due date of 30 November.
What is the penalty for not filing Form 3CEB?
A fixed penalty of Rs. 1,00,000 under Section 271BA, in addition to documentation penalties of 2% of transaction value under Sections 271AA and 271G where the underlying records are missing.
Is Form 3CEB different from the tax audit report?
Yes. The tax audit report (Form 3CD) covers general tax compliance, while Form 3CEB is a separate, transaction-wise transfer pricing certification; many businesses need both, and the two must reconcile.
Form 3CEB due and transactions not yet mapped?
We'll capture, benchmark, certify, and file before the deadline — penalty-proof.
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