Form 3CEB Format — Transfer Pricing Accountant's Report (Section 92E)

The Section 92E accountant's report on international and specified domestic transactions with associated enterprises — transaction-by-transaction disclosure, arm's length method applied, and the required annexure structure.

Free · CORAA original — SA-aligned

Updated 28 Jul 2026

Statutory basis

Section 92E, Rule 10E

Applies to

International + specified domestic transactions with AEs

Filed with

Income-tax e-filing portal, before the Sec 44AB due date

Not this document

The transfer pricing study/documentation itself (Rule 10D) — a separate, more detailed record

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Your firm — letterhead

Appears at the top of the document as the audit firm letterhead.

Audit firm name

Audit firm address

Used as the letterhead block.

Engagement partner

ICAI membership no.

Firm registration no.(optional)

Engagement details

The client and period this document is for.

Name of assessee

PAN

Address of assessee

Status

Previous year ended

Assessment Year

GSTIN (if registered)(optional)

Date of report

Associated enterprise — name

Nature of relationship (Sec 92A test)(optional)

Nature of the international / specified domestic transaction(optional)

Arm's length pricing method applied

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Form 3CEB Format — Transfer Pricing Accountant's Report

31 July 2026

FORM No. 3CEB

[See rule 10E] — Report from an accountant to be furnished under section 92E of the Income-tax Act, 1961, relating to international transactions and specified domestic transactions.

We have examined the accounts and records of {{client_name}} (PAN: {{client_pan}}) relating to international transactions and specified domestic transactions entered into by the assessee during the previous year ended {{period_end}}, relevant to Assessment Year {{assessment_year}}.

Part A — General particulars

Particulars	Details
Name of the assessee	{{client_name}}
Address	{{client_address}}
PAN	{{client_pan}}
Previous year ended	{{period_end}}
Assessment year	{{assessment_year}}

Part B — Particulars of associated enterprise(s)

Particulars	Details
Name of the associated enterprise	{{associated_enterprise_name}}
Nature of relationship (Section 92A test — share capital/voting power/management/loan/guarantee, etc.)

Part C — Particulars of the international transaction / specified domestic transaction

Particulars	Details
Nature of transaction
Value of the transaction as recorded in the books	____________
Arm's length price of the transaction	____________
Method used for determining the arm's length price	TNMM

We certify that the above particulars are true and correct to the best of our knowledge and belief, and are based on the records, documents, and explanations produced before us. This report does not represent an opinion on the correctness of the arm's length price adopted — that determination and its supporting transfer pricing study/documentation (maintained under Rule 10D) remain the responsibility of the assessee.

For {{firm_name}}

Chartered Accountants

Firm Registration No.:

_______________________________

Partner

Membership No.: {{icai_membership_no}}

UDIN: ____________________

Place: ____________________

Date: 31 July 2026

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What’s inside

An excerpt from the template.

FORM No. 3CEB

[See rule 10E] — Report from an accountant to be furnished under section 92E of the Income-tax Act, 1961, relating to international transactions and specified domestic transactions.

We have examined the accounts and records of ___ (PAN: ___) relating to international transactions and specified domestic transactions entered into by the assessee during the previous year ended ___, relevant to Assessment Year ___.

Part A — General particulars

↑ Excerpt only — the full template is what you download as Word

About this template

What you’re downloading, and when to use it.

This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

Everything is generated in your browser and on a stateless API endpoint — no account, nothing stored on our servers. We’ll ask for a work email once before your first download so we can send you the file and the occasional relevant update; after that, downloads on this device are instant. Edit freely in Word, Google Docs or Pages before sending to your client.

Common questions

FAQs.

Who is required to obtain a Form 3CEB report?

Every person who has entered into an international transaction, or a specified domestic transaction above the prescribed aggregate value, with an associated enterprise (as defined under Section 92A) during the previous year must obtain this accountant's report and furnish it electronically before the Section 44AB due date, regardless of whether the entity is otherwise subject to tax audit.

Does Form 3CEB itself prove the transaction was at arm's length?

No — the form only certifies that the particulars disclosed (transactions, associated enterprises, method applied) are true and correct based on the records examined. It is not an opinion on whether the price charged was actually at arm's length; that substantive analysis lives in the transfer pricing study and contemporaneous documentation maintained under Rule 10D, which the assessing officer or Transfer Pricing Officer can call for separately.

What happens if Form 3CEB is not filed or is filed late?

Section 271BA prescribes a penalty (a fixed sum, verify the current amount) for failure to furnish the report by the due date. Separately, failure to maintain the underlying Rule 10D documentation, or furnishing incorrect information, attracts its own penalties under Sections 271AA and 271G — these are distinct from, and in addition to, the 271BA penalty for the report itself.

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