TRANSFER PRICING COMPLIANCE CHECKLIST
Chapter X of the Income-tax Act · Form 3CEB due 31 October 2026 · FY 2025-26
Applicability
- ☐ Identify associated enterprises (AE) as per Section 92A
- ☐ List all international transactions with AEs
- ☐ Identify specified domestic transactions above the threshold
- ☐ Confirm any transactions with entities in notified jurisdictions
Analysis & Benchmarking
- ☐ Perform a functions, assets and risks (FAR) analysis
- ☐ Select the most appropriate method (CUP, RPM, CPM, TNMM, PSM)
- ☐ Carry out a comparability / benchmarking study
- ☐ Determine the arm’s length price and any range / adjustment
Documentation
- ☐ Maintain the Rule 10D contemporaneous documentation
- ☐ Prepare the Master File (Form 3CEAA) if thresholds are met
- ☐ Prepare Country-by-Country Report (3CEAD) for large groups
- ☐ Retain inter-company agreements and invoices
Reporting
- ☐ Obtain the accountant’s report in Form 3CEB with UDIN
- ☐ File Form 3CEB by 31 October 2026
- ☐ Report any voluntary arm’s length adjustment in the ITR
Non-maintenance of documentation or non-filing of Form 3CEB attracts steep penalties under Sections 271AA and 271BA; keep the study contemporaneous with the transactions.