Form 3CEB becomes Form 48 from Tax Year 2026-27
Summary
Under section 172 of the Income-tax Act, 2025 and Rule 85 of the 2026 Rules, the accountant's transfer-pricing report becomes Form 48. Form 3CEB still applies up to 2025-26 (AY 2026-27); Form 48 applies from Tax Year 2026-27.
Key points
- ₹1 lakh penalty for not filing the report
- 2% of the transaction value for documentation failures (s.457)
- Sections: old 92E → new 172, old 92D → new 171
For Korean companiesIf HQ checklists or your accountant's engagement letter say 'Form 3CEB', update them to 'Form 48' for filings from 2027. Adullam adds the Form 48 due date to the calendar as soon as it is notified.