Form 3CEAA master file sheet for CA firms: which group-company clients file Part A or Part B by 30 November 2026, and Form 3CEAB by 31 October (AY 2026-27)
What you get: a ready-to-copy Google Sheet layout with one row per client entity that belongs to a foreign or Indian multinational group. Formulas tell you, for AY 2026-27 (FY 2025-26), whether each entity needs Form 3CEAA (master file) Part A only or Part A + Part B, whether a Form 3CEAB designation is due first, and the date for each: "File 3CEAB by 31 Oct, then 3CEAA by 30 Nov", "Covered by designated entity", "Done" or "PAST DUE". Plus a plan to 30 November, three made-up example rows and two client messages. Free, no sign-up.
Short answer (checked 22 Oct 2026): every constituent entity of an international group must furnish Part A of Form 3CEAA, even if it is below the thresholds (Rule 10DA(3), Income-tax Rules, 1962). The full master file (Part B) is needed only if the group's consolidated revenue for the accounting year exceeds ₹500 crore and the entity's international transactions exceed ₹50 crore, or its intangible-property transactions exceed ₹10 crore (Rule 10DA(1)). Form 3CEAA is due on or before the due date for the return under section 139(1) (Rule 10DA(2), as substituted by Notification No. 03/2020, G.S.R. 14(E), 6 Jan 2020). For an entity that files a section 92E (Form 3CEB) report, that is 30 November 2026, a Monday (department's return of income page, Sl. No. 1). Where a group has more than one constituent entity resident in India and wants only one of them to file, the designation must be conveyed in Form 3CEAB thirty days before the Form 3CEAA due date (Rule 10DA(4)): against 30 November that is 31 October 2026, a Saturday. This is a starting point, not tax advice.
Which date applies to each client entity (AY 2026-27)
| Client entity | Section 139(1) due date | Form 3CEAA by | Form 3CEAB (only if designating one Indian entity) by |
|---|---|---|---|
| Constituent entity that must file a section 92E report (Form 3CEB) | 30 November 2026 (not extended) | Mon 30 November 2026 | Sat 31 October 2026 (aim for Fri 30 Oct) |
| Constituent entity (company or audited non-company) with no section 92E report | 21 November 2026 (31 October, extended by Circular 07/2026) | Sat 21 November 2026 at the latest | Thu 22 October 2026 at the latest, counting 30 days back from 21 November |
CBDT Circular No. 07/2026 (28 Sep 2026) extended the return due date for AY 2026-27 only for Sl. No. 2 of the due-date table (audit cases where section 92E does not apply), from 31 October to 21 November 2026. It does not mention Form 3CEAA or Form 3CEAB, and transfer pricing cases stay at 30 November. Most constituent entities with cross-border dealings with group companies have a section 92E report, so 30 November is the date for most rows; for the rest, file well before 21 November and check the due date the e-filing portal accepts.
Tab "entities": one row per client entity
| Column | What goes in it |
|---|---|
| A Client entity | Name |
| B Group | Name of the international group |
| C Constituent entity of an international group? | Yes / No (use the definitions in section 286; if No, nothing in this sheet applies) |
| D Group accounting year | For example "Jan–Dec 2025" or "Apr 2025–Mar 2026" (Form 3CEAA Part A asks for it) |
| E Consolidated group revenue (₹ crore) | From the group's consolidated financial statement for the accounting year; foreign currency converted at the telegraphic transfer buying rate on the last day of that year (Rule 10DA) |
| F International transactions in FY 2025-26 (₹ crore) | Aggregate value as per the books |
| G Intangible-property transactions (₹ crore) | Purchase, sale, transfer, lease or use of intangible property, as per the books |
| H Section 92E report (Form 3CEB) required? | Yes / No |
| I Other constituent entities resident in India | Number (0 if this is the only one) |
| J Designated entity | "Self" if the group designated this entity to file for all, the other entity's name if it designated someone else, or blank |
| K Form 3CEAA due | Formula below |
| L Form 3CEAB due | Formula below |
| M Parts to file | Formula below |
| N 3CEAB filed on | Date (blank until filed) |
| O 3CEAA filed on | Date (blank until filed) |
| P Action | Formula below |
| Q Flag | Formula below |
K2: =IF(C2<>"Yes","",IF(H2="Yes",DATE(2026,11,30),DATE(2026,11,21)))
L2: =IF(OR(C2<>"Yes",I2<1,J2<>"Self"),"",K2-30)
M2: =IF(C2<>"Yes","Not applicable",IF(AND(E2>500,OR(F2>50,G2>10)),"Part A + Part B","Part A only"))
P2: =IF(C2<>"Yes","No Form 3CEAA",
IF(AND(I2>=1,J2<>"",J2<>"Self"),"Designated entity "&J2&" files: keep a copy of its 3CEAB and 3CEAA",
IF(O2<>"","Done: 3CEAA filed "&TEXT(O2,"d mmm"),
IF(AND(J2="Self",N2=""),"File 3CEAB by "&TEXT(L2,"d mmm")&", then 3CEAA ("&M2&") by "&TEXT(K2,"d mmm"),
"File 3CEAA ("&M2&") by "&TEXT(K2,"d mmm")))))
Q2: =IF(AND(C2="Yes",O2="",TODAY()>K2,LEFT(P2,4)="File"),"PAST DUE: section 271AA(2) exposure",
IF(AND(L2<>"",N2="",TODAY()>L2),"3CEAB date passed: check whether each Indian entity must file its own 3CEAA",""))
Sort by K, then P, so every "File 3CEAB by 31 Oct" row is on top. Thresholds use ">" because the rule says "exceeds": a group at exactly ₹500 crore is Part A only.
Three made-up example rows (not real clients)
| A | E | F | G | H | I | J | P result |
|---|---|---|---|---|---|---|---|
| Example Components India Pvt Ltd | 2,400 | 85 | 3 | Yes | 1 | Self | File 3CEAB by 31 Oct, then 3CEAA (Part A + Part B) by 30 Nov |
| Sample Sales India LLP | 2,400 | 12 | 0 | Yes | 1 | Example Components India Pvt Ltd | Designated entity Example Components India Pvt Ltd files: keep a copy of its 3CEAB and 3CEAA |
| Demo Software India Pvt Ltd | 320 | 40 | 0 | Yes | 0 | (blank) | File 3CEAA (Part A only) by 30 Nov |
Tab "part-b-pack": what Part B asks for (for "Part A + Part B" rows)
One row per item, with columns Item, Asked from (group tax team / Indian finance), Requested on, Received on, Notes. The items, from Rule 10DA(1) and Form 3CEAA Part B:
- List of all group entities with addresses, and a chart of legal status and ownership of the whole group.
- Business description: nature of the businesses, profit drivers, supply chain for the five largest products or services and any others above 5% of group revenue, important service arrangements, transfer pricing policies for intra-group services, major geographical markets, functions-assets-risks of entities contributing at least 10% of revenue, assets or profits, and important restructurings, acquisitions and divestments.
- Intangibles: overall strategy and principal R&D locations, entities that develop and manage intangibles, important intangibles and their legal owners, related agreements (cost contribution, research services, licences), transfer pricing policies for R&D and intangibles, and important transfers of interests in intangibles.
- Financing: financing arrangements with the top ten unrelated lenders, entities providing central financing functions, and transfer pricing policies for intra-group financing.
- A copy of the annual consolidated financial statement, and a list of existing unilateral APAs and other tax rulings on allocating income between countries.
Foreign parents usually hold most of this in their group master file, so the "Requested on" date matters more than anything else in this tab: ask this week.
The rules the formulas follow
- Part A for everyone in the group: name, address and PAN of the entity, the group's name and address, the accounting year, and the number, names, PANs and addresses of all constituent entities in India. Required even below the thresholds (Rule 10DA(3)).
- Part B only above both tests: group revenue over ₹500 crore and international transactions over ₹50 crore, or intangible-property transactions over ₹10 crore (Rule 10DA(1)).
- Due date: on or before the section 139(1) return due date (Rule 10DA(2)).
- One filer for the group: only where the group has more than one constituent entity resident in India, has designated one of them, and that has been conveyed in Form 3CEAB thirty days before the Form 3CEAA due date (Rule 10DA(4)). If that does not happen, plan on each entity filing its own Form 3CEAA.
- Penalty: failing to furnish the information and document required under section 92D(4) can attract a penalty of ₹5,00,000 under section 271AA(2), levied by the prescribed authority; section 273B allows a reasonable-cause defence.
Plan to 30 November
| When | What |
|---|---|
| Thu 22 – Sat 24 Oct | List every client entity that belongs to an international group (columns A–I). Ask each group which entity, if any, it designates to file for India (J). Send message 1. |
| Mon 26 – Fri 30 Oct | File Form 3CEAB for every "Self" row with a 30 November due date by Friday 30 October, not Saturday 31 October. Record the date (N). |
| Mon 2 – Fri 13 Nov | Fill Part A for every row. For "Part A + Part B" rows, chase the part-b-pack tab and send message 2 to any group that has not replied. |
| Mon 16 – Fri 20 Nov | File Form 3CEAA for any row whose due date is 21 November. Review Part B drafts. |
| Mon 23 – Fri 27 Nov | File the remaining Form 3CEAA. Keep Monday 30 November as a buffer only. |
Two client messages
1. Group designation: "Your company is part of an international group, so it must file Form 3CEAA (master file) by 30 November 2026. If the group has more than one entity in India and wants only one of them to file for all, that entity must file Form 3CEAB by 31 October 2026. Please confirm by [date] which Indian entity, if any, the group designates, and send last year's group consolidated revenue and accounting year."
2. Part B documents: "Your group's revenue and your international transactions are above the limits for the full master file (Part B of Form 3CEAA). Please ask the group tax team for the group master file, ownership chart, consolidated financial statements and list of APAs and tax rulings for the accounting year by [date], so we can file before 30 November 2026."
Notes
- This sheet is for AY 2026-27 (FY 2025-26) under the Income-tax Act, 1961 and the 1962 Rules. From tax year 2026-27 the master file moves to rule 123 of the Income-tax Rules, 2026, as Form No. 56 with the designation in Form No. 57, keeping the same ₹500 crore / ₹50 crore / ₹10 crore tests and the thirty-day designation window.
- Country-by-country reporting (Form 3CEAC, 3CEAD, 3CEAE) has different dates and is not covered here.
- The sheet holds group financial data: share it only inside your firm.
Related guides
- Form 3CEB transfer pricing client chase list
- ITR audit cases: 21 Nov 2026 chase list
- Form 10-IEA sheet (21 Nov 2026)
- November 2026 due-date chase list
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