Tax Audit
    Service

    Transfer Pricing Report (Form 48 / 3CEB).

    If you transact with associated enterprises abroad, or have specified domestic transactions, you must obtain an accountant's report on those transactions every year. It now falls under section 172 of the Income-tax Act, 2025, in Form No. 48 (previously section 92E and Form 3CEB). We review your transfer pricing documentation, test the arm's length position and file the report.

    See how it works

    Free 30-minute call with a partner

    About Transfer Pricing Report (Form 48 / 3CEB). No obligation — we reply within one business day.

    Typical timeline

    Typically 1–2 weeks once the accounts are final and the transfer pricing documentation is ready. The number of associated enterprises and transaction types drives the time.

    Who leads it

    A partner — a chartered accountant or company secretary — from the first call to sign-off.

    Fees

    Based on your situation, and fixed in writing before any work starts.

    Who it's for

    Is this for you?

    • Indian subsidiaries and branches of foreign groups
    • Indian companies with overseas subsidiaries, joint ventures or related parties
    • Businesses with specified domestic transactions above the prescribed limit
    • Groups with cross-border royalties, service fees, guarantees or loans
    What you get

    What you receive at the end.

    • 01Accountant's report: Form 3CEB for financial year 2025-26; Form No. 48 from tax year 2026-27
    • 02Reconciliation of reported transactions to the books
    • 03Note on documentation gaps and risk areas
    • 04Filing acknowledgement from the e-filing portal
    How it works

    Transfer Pricing Report (Form 48 / 3CEB), step by step.

    Typical timeline

    Typically 1–2 weeks once the accounts are final and the transfer pricing documentation is ready. The number of associated enterprises and transaction types drives the time.

    1. 1

      Transaction mapping

      We identify your associated enterprises and list every international and specified domestic transaction from the books.

    2. 2

      Documentation review

      We review your transfer pricing study, benchmarking and intercompany agreements, and flag gaps to close before reporting.

    3. 3

      Arm's length testing

      We check the method applied and whether prices fall within the arm's length range, and note any adjustments.

    4. 4

      Report preparation

      We complete the report clause by clause and reconcile the values reported to the financial statements.

    5. 5

      Signing and filing

      We sign and upload the report on the e-filing portal for your approval, at least one month before the return due date.

    Before we start

    What we need from you.

    Don't have everything yet? We send a short checklist after the first call and work with what you have.

    • Group structure chart and list of associated enterprises
    • Intercompany agreements and invoices
    • Transfer pricing documentation and benchmarking study
    • Audited financial statements and segmental data
    • Details of specified domestic transactions, if any
    • Previous year's accountant's report and any transfer pricing orders
    How fees work

    The fee depends on your situation. After a short call, the partner who will do the work tells you what's involved and gives you a fixed fee in writing — before any work begins.

    • Government fees and statutory charges are billed at actuals.
    • When you pay — upfront, in stages or on completion — is agreed in writing with the fee.
    FAQs

    Questions about Transfer Pricing Report (Form 48 / 3CEB).

    No. Documentation is the study that supports your prices; the accountant's report certifies the transactions and is filed with the tax department. You need both, and we can prepare the documentation as a separate engagement.

    Speak with a partner

    Ready to discuss Transfer Pricing Report (Form 48 / 3CEB)?

    30-minute confidential call — no proposal, no commitment. A partner will write back within one business day.

    Contact details