Chartered Accountants in India, working with clients across Europe

+91 9819 000 511 clientdesk@savlagroup.in nainitsavla@savlagroup.in
Book a consultationBook a call
Transfer Pricing Audit and Form 48 (Old 3CEB) | NDSA
TP audit · Accountant’s report

Your TP report, certified and on time.

Every Indian entity with international or specified domestic transactions files an accountant’s report each year: Form 3CEB, now Form 48. It sits within a tight calendar. Here it is.

Get my Form 48 WhatsApp us
Form 48Replaces 3CEB
Section 172New Act
CACertifies it
The TP compliance calendarFor companies with TP
By31 OctoberForm 48Accountant’s TP report
By30 NovemberIncome tax returnFor TP cases
By30 NovemberMaster fileFor larger groups
Within12 monthsCbC reportAfter group year-end, where required
OngoingEach yearDocumentationKept ready for review

Dates as they usually apply; check each year for extensions.

01 · What it covers

What the report sets out.

Associated enterprises

Every related party and the relationship.

CoversGroup companies
NewSection 162 test
CheckCompleteness
Ask us about this
02 · Our process

From books to certified report.

  1. 1
    Reconcile

    Transactions

    Books, agreements and invoices.

  2. 2
    Review

    The TP study

    Method and benchmarking.

  3. 3
    Verify

    Values and ALP

    Against documentation.

  4. 4
    Certify

    Form 48

    Filed online.

  5. 5
    Align

    With the return

    Same figures in both.

03 · Pitfalls

Where TP reports go wrong.

Missing

Transactions left out

Unreported transactions invite adjustments and penalties.

Mismatch

Different figures

The report and the return disagree.

Late

Filed after the due date

A fee applies under the new Act.

04 · Common myths

TP audit myths.

Related services

More on transfer pricing.

Related pages.

Transfer pricing

TP disputes

Planning

Business compliance

Wherever you live in Europe

TP audits for groups across Europe.

We certify TP reports for Indian entities of groups in every EU country, Switzerland and Norway.

BerlinMunichFrankfurtHamburgStuttgartAmsterdamRotterdamThe HagueEindhovenBrusselsAntwerpLuxembourgParisLyonToulouseDublinCorkStockholmGothenburgCopenhagenHelsinkiOsloZurichGenevaViennaMilanRomeMadridBarcelonaLisbonPortoWarsawKrakówPragueBudapestBucharestTallinnVilniusAthensValletta
05 · FAQs

TP audit questions answered.

What is a TP audit?
Certification of TP transactions in Form 48.
What did Form 48 replace?
Form 3CEB.
When is it due?
Usually by 31 October.
Who signs it?
A chartered accountant.
What if it’s late?
A fee applies.
Do reimbursements count?
Yes.
Is a master file separate?
Yes, for larger groups.
What is the CbC report?
Group reporting for very large groups.
Must figures match the return?
Yes.
Can you certify ours?
Yes.

Form 48 due? Start with the transactions.

Share your intercompany ledgers and agreements. We’ll prepare and certify the report.

Get my Form 48 +91 9819 000 511

General guidance based on the rules as they stand, including the Income-tax Act, 2025 and the Income-tax Rules, 2026. It is not legal, tax or financial advice for your situation; please contact us before acting on it.