Form 3CEB chase list for CA firms: transfer-pricing clients, report by 31 October, ITR by 30 November 2026 (AY 2026-27)
Short answer (checked 20 Oct 2026): For AY 2026-27 (FY 2025-26), the accountant's report in Form 3CEB under section 92E of the Income-tax Act, 1961 is due on Saturday 31 October 2026, and the income-tax return of an assessee who must furnish Form 3CEB (companies, other assessees and partners of such firms) is due on Monday 30 November 2026 (Income Tax Department, periods of limitation, AY 2026-27). CBDT Circular 07/2026 of 28 September 2026 moved only the ordinary audit cases at Sl. No. 2 (return to 21 Nov, audit report to 21 Oct). It does not move these dates. This is a starting point, not tax advice. Confirm on the Income-tax e-filing portal before you file.
What you get from this guide: a finished 11-day chase plan that gets every transfer-pricing client's Form 3CEB uploaded and accepted by the client on the portal by Friday 30 October 2026, one day before the Saturday due date. Sort every client with dealings with a foreign group company into one of three groups: 3CEB needed and data in hand (finish and upload now), 3CEB needed but transaction data or documentation missing (chase today), and not sure whether 3CEB applies (partner decides by 22 Oct). The one-row-per-client sheet, the collect list and short client scripts are below. Copy them into your own sheet.
The dates and rules you can rely on
| What | Who | Rule | Date |
|---|---|---|---|
| Accountant's report, Form 3CEB, AY 2026-27 | Anyone who entered into an international transaction or specified domestic transaction in FY 2025-26 | s.92E; due 31 October of the assessment year | 31 Oct 2026 (Sat) |
| Tax audit report (3CA/3CB with 3CD) for the same client, if audited | Transfer-pricing clients who are also under s.44AB | Specified date is one month before the s.139(1) due date (Explanation to s.44AB); the 21 Oct date in Circular 07/2026 is only for Sl. No. 2 cases | 31 Oct 2026; confirm on the portal |
| Income-tax return, AY 2026-27 | Corporate and non-corporate assessees, including partners of the firm, who must furnish Form 3CEB | s.139(1), Explanation 2 | 30 Nov 2026 (Mon) |
| Ordinary audit cases (no 3CEB) | Sl. No. 2 of the table below Explanation 2 to s.139(1) | Circular 07/2026 | Audit report 21 Oct, ITR 21 Nov 2026 |
| Master file (Form 3CEAA) and country-by-country report (Forms 3CEAC / 3CEAD) | Constituents of international groups above the thresholds in rule 10DA / 10DB | s.92D(4), s.286 | Check the official source |
Why "upload by 30 Oct" and not "by 31 Oct": 31 October is a Saturday, and a Form 3CEB is not done when the CA uploads it: the client still has to log in and accept it on the portal. Signatories travel, DSCs expire, and the portal is busiest on the last day. Treat any later extension as a bonus, not a plan.
The easy mistake this year: a client with both a tax audit and foreign group transactions reads "audit extended to 21 November" in the news and relaxes. Their dates did not move. Tell them this week, in writing.
What a late or missing report costs: failure to furnish the s.92E report attracts a penalty under s.271BA; check the current text before you quote an amount to a client. If the return goes in after 30 November, the fee under s.234F (₹5,000, or ₹1,000 where total income does not exceed ₹5 lakh; incometaxindia.gov.in), interest under s.234A on unpaid tax, and the loss carry-forward bar (s.80 read with s.139(3)) apply.
11-day chase plan (20 Oct–31 Oct 2026)
| When | Who | What to ask for or do | Tone tip |
|---|---|---|---|
| Tue 20–Wed 21 Oct | Every client with a foreign parent, subsidiary, branch or group company | Send one message: "Your transfer-pricing report is due 31 October and your return 30 November. The 21 November extension does not apply to you." Sort each client into its group on the sheet. | Lead with the date, not the law |
| By Thu 22 Oct | Group 3 (not sure) | Partner decides whether Form 3CEB applies: any transaction with an associated enterprise (s.92A) in FY 2025-26, including cost recharges, guarantees, loans, interest, royalty, share issues and reimbursements. Record the decision and the reason. | "No 3CEB" is a decision too: write it down |
| By Fri 23 Oct | Group 2 (data missing) | Get the transaction listing by associated enterprise and nature, agreements, intercompany invoices and the year-end balance confirmation. Tie totals to the audited accounts. | Send one list of gaps, not item by item |
| Sat 24–Tue 27 Oct | Groups 1 and 2 | Finish the documentation review (rule 10D records, method and comparables), draft Form 3CEB, and send the client the draft with a one-page summary of each transaction and value. | Ask the client to confirm values, not to review the law |
| Wed 28 Oct | All 3CEB clients | Client confirms the draft. Check the signatory's DSC is valid and registered on the portal and that the client is assigned to your CA login for the form. | Fix DSC and assignment today, not on the 31st |
| Thu 29–Fri 30 Oct | All 3CEB clients | Upload Form 3CEB (and the tax audit report, if not done). Generate the UDIN. Ask the client to accept on the portal the same day. Note the acknowledgement number. | "Please accept today" with the steps in the message |
| Sat 31 Oct | Internal only | Due date buffer. Note the acknowledgement, or the written reason, for every client still pending, and tell the client in writing what a missing report costs. | Never upload on presumed consent |
| 2–27 Nov | All 3CEB clients | Return: the ITR must agree with the 3CEB values. Compute tax and interest, collect "OK to file", and file and verify by Fri 27 Nov, ahead of Mon 30 Nov. | Same one-page summary, updated |
The one-row-per-client sheet
| Client and PAN | Group (1 / 2 / 3) | Associated enterprises and countries | Transactions by nature and value (₹) | Documentation (rule 10D) status | Tax audit report ack (if audited) | 3CEB uploaded (ack, UDIN) / client accepted (date) | Master file / CbCR flag | ITR filed (ack) / verified (date) |
|---|---|---|---|---|---|---|---|---|
| Client A, client PAN | 1 | parent company, country | services fee ₹; cost recharge ₹; loan interest ₹ | method, comparables done / pending | ack no., date | ack no., UDIN / date | none / 3CEAA / 3CEAC | ack no., date |
One tab per partner handling the files, and a filter on the "client accepted" column, is your daily status report from now to 31 October. A second filter on the last column carries you to 30 November.
Collect list for each transfer-pricing client
- List of associated enterprises with country, relationship (s.92A) and the agreements in force in FY 2025-26
- Transaction listing by enterprise and nature (purchases, sales, services, royalty, cost recharges, reimbursements, loans and interest, guarantees, share issues), tied to the audited accounts
- Intercompany invoices, debit and credit notes, and year-end balance confirmations
- Specified domestic transactions under s.92BA, if any; check whether they apply for this client
- Transfer-pricing documentation kept under rule 10D: functions, assets and risks, method chosen, comparables and the working
- Last year's Form 3CEB and any transfer-pricing order or advance pricing agreement for the client
- Signatory's DSC valid and registered on the e-filing portal; client login available to accept the form
- Remittances to group companies during the year with the Form 15CA/15CB references, so the values match
- Group revenue and parent details to decide whether the master file (Form 3CEAA) or country-by-country forms apply; check the official source for thresholds and dates
Clients ask fewer "is my date extended too?" questions when the dates sit on a one-page calendar with your firm's name on it. Free national dates and a browser .ics builder: free CA due-date calendar tool.
WhatsApp / email script pack
Your date did not move: "Hello. You may have seen that the income-tax audit deadline was extended to 21 November. That extension does not apply to you because you have transactions with group companies abroad. Your transfer-pricing report (Form 3CEB) is due 31 October and your return 30 November. We plan to upload the report by 30 October."
Data request: "To finish your Form 3CEB we need, by [date]: the list of all transactions with [group companies] in 2025-26 with values, the agreements, and the year-end balance confirmation. A template is attached; please fill one row per transaction."
Confirm the draft: "The draft Form 3CEB is attached with a one-page summary of each transaction and its value. Please reply 'confirmed' by [date], or tell us which value is different."
Accept on the portal: "We have uploaded your Form 3CEB. Please log in to the income-tax e-filing portal, open Worklist, and accept the form today. The last date is Saturday 31 October. Reply 'done' once accepted."
Return next: "Your report is filed. Your income-tax return is due Monday 30 November; we plan to file by 27 November. Please send [list] by [date]."
Partner programme opening soon
Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.
If you want branded quarterly packs
The White-Label Client Compliance Calendar for CA Firms (₹999/year) sends four quarterly packs with your firm name on the DOCX, PDF and WhatsApp image, plus national .ics/.xlsx and extension notes, so split dates like 21 November for audit cases and 30 November for transfer-pricing cases reach every client's page. Files are made after checkout (not instant). 14-day refund from when you receive the first pack. Disclosure: that is an Unadhi product. You can use this chase list without buying anything.
This guide is general information, not tax advice and not an official government publication. Circulars, forms and dates can change by notification. Check the Income-tax e-filing portal and the current circular before you file or message clients. Your firm stays responsible for advice to your clients.
Sources to re-check
- Income Tax Department, periods of limitation, AY 2026-27 (Income-tax Act, 1961 as amended by the Finance Act, 2026): s.92E report 31 October of the assessment year; s.139(1) return 30 November where Form 3CEB is required; s.44AB report one month before the s.139(1) due date: incometaxindia.gov.in
- CBDT Circular No. 07/2026, 28 Sep 2026 (extends only Sl. No. 2: ITR 31.10.2026 → 21.11.2026; audit report → 21.10.2026): incometaxindia.gov.in
- CBDT press release, 28 Sep 2026: incometaxindia.gov.in
- e-filing portal, forms for business and profession (Form 3CEB to be furnished at least one month before the return due date): incometax.gov.in
- Income Tax Department, interest and fees (s.234F): incometaxindia.gov.in
- Related guides: ITR chase list for audit cases (21 Nov) · tax audit report due 21 Oct 2026 · Form 15CA/15CB for foreign remittances · what belongs on a white-label calendar
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.