Form 3CEAA: Master File Filing Requirements & Due Date 2026
Most people hear “master file” and assume it is only for huge multinationals. That is true for Part B. Part A of Form 3CEAA has no turnover or transaction threshold, and it catches many Indian subsidiaries, branches and joint ventures that never thought of themselves as part of a “group”. For FY 2025-26 (AY 2026-27), the date most entities should work to is 30 November 2026.
What is the Master File, and what is Form 3CEAA?
The master file is a group-level document required under section 92D(2) and Rule 10DA of the Income-tax Act, 1961. The idea is simple. When the tax department looks at an Indian entity’s transfer pricing, it also wants to see the wider group: who the entities are, what each one does, and how money and intangibles move between them.
The information goes in Form 3CEAA, which has two parts.
Part A is basic identification. It names the Indian entity and its PAN, and identifies the group, including the ultimate parent and the country where that parent is resident.
Part B is the detailed disclosure on the group’s structure, business, intangibles, intercompany financing, and financial and tax position.
Form 3CEAA is separate from Form 3CEB. The 3CEB is the accountant’s report on your own international transactions. The master file is about the group.
Who must file Part A?
Every Indian entity that is a constituent entity of an international group must file Part A. There is no minimum revenue, no minimum transaction value, and no requirement that you actually transacted with another group company during the year.
An international group, broadly, is a set of entities in different countries that are linked through ownership or control, and that either prepare consolidated financial statements or would have to if their shares were listed. The definitions follow the ones used for country-by-country reporting.
In practice, Part A is relevant to:
- An Indian company, LLP or partnership firm that is a subsidiary of a foreign parent.
- An Indian parent, whether a company, LLP or partnership firm, that holds overseas subsidiaries.
- Joint ventures and other Indian entities that would sit inside a group’s consolidated accounts.
- Where applicable, Indian branches or permanent establishments of overseas group companies.
For example:
Take an Indian partnership firm that holds 80% of the shares in a company outside India. The firm does not prepare consolidated accounts, and the law does not make it do so. Many people stop there and conclude there is no group. That is the wrong test. The definition asks whether consolidation would be required if the firm’s equity were listed. With 80% and control, the answer is yes, so the firm and the overseas company form an international group. The firm is the parent, and it files Part A as the Indian constituent entity. Now change the holding to 10%, with no say in running the company. There is no control, so there is most likely no group and no Part A filing. Between the two sits the 20% to 50% band, where the company is an associate and the answer needs a documented view. Either way, the actual holding percentage decides the outcome, so check it before the due date.
A grey area worth flagging. Sometimes the only link between an Indian entity and an overseas company is common ownership by the same individuals, with neither entity holding the other. In that case, it is not always clear that an international group exists. This is a judgment call. Whichever view you take, write down the reasoning and apply it the same way every year.
When does Part B apply, and what is the due date?
Part B is required only when both of these conditions are met for the year.
| Condition | Threshold |
|---|---|
| Consolidated revenue of the international group for the year | International transactions of the Indian entity, as per its books |
| More than ₹500 crore | More than ₹50 crore, or more than ₹10 crore if they relate to intangible property |
If either condition is not met, you file Part A only.
Due date. Form 3CEAA is due on or before the due date for furnishing the return of income under section 139(1). For entities that also need a Form 3CEB, that return date is 30 November 2026, so most groups plan the master file around that date. Entities with no transfer pricing report follow their own return date, so check which one applies to you. For tax audit cases without a 3CEB, the return date for this year was extended to 21 November 2026 by a CBDT circular. That is an extension and not the normal statutory date, so working to the earlier date is the safer approach.
Form 3CEAB. If a group has more than one Indian constituent entity, it can designate one of them to furnish the Part B information for the group. This is intimated in Form 3CEAB, at least 30 days before the Form 3CEAA due date. For a 30 November filing that meant about 31 October. The designation covers Part B only. Every Indian constituent entity still has to file its own Part A.
Next year. Under the Income-tax Act, 2025, the equivalent forms are reported to be Form 56 (master file) and Form 57 (designation) from Tax Year 2026-27. FY 2025-26 is still governed by the 1961 Act.
What happens if you miss it?
Failing to furnish the master file information can attract a penalty of ₹5 lakh under section 271AA. Separate penalties of up to 2% of the value of each international transaction apply if transfer pricing documentation is not maintained, or a transaction is not reported properly in Form 3CEB. Late or missing filings also tend to invite questions during assessment, which costs more time than the form itself.
A simple preparation checklist
- List every entity in your group, with its country and ownership percentages.
- Confirm whether the group prepares, or would be required to prepare, consolidated financial statements.
- Collect the ultimate parent’s details: name, address, country of residence, and PAN if it has one.
- If you have several Indian entities, decide which one furnishes Part B and record the designation. Each entity still files its own Part A.
- Test the two Part B thresholds against the group’s latest consolidated revenue and your own international transactions.
- File Form 3CEAA electronically on the income-tax portal before the due date, and keep a copy with your transfer pricing file.
Conclusion
Form 3CEAA is easy to overlook because most of the attention goes to Form 3CEB. But Part A is a basic filing for any Indian entity that sits inside a cross-border group, and missing it is an avoidable penalty. Work out whether you are part of an international group, confirm who files, and keep the 30 November date in your calendar.
If you are not sure whether your structure counts as a group, or you want Form 3CEAA and Form 3CEB handled together, our transfer pricing consultants can help. Write to us at enquire@kdpaccountants.com.
FAQs
Does a small group still need to file Part A?
Yes. Part A has no revenue or transaction threshold. Only Part B depends on the ₹500 crore and ₹50 crore (or ₹10 crore) tests.
Do I need to file if I had no international transactions this year?
The Part A obligation comes from being a constituent entity of an international group, not from the number of transactions. Having no transactions does not by itself remove the requirement.
Can one Indian entity file for the whole group?
Only for Part B. The group can designate one Indian entity to furnish Part B through Form 3CEAB within the prescribed time. Every Indian constituent entity must still file its own Part A.
Is Form 3CEAA the same as Form 3CEB?
No. Form 3CEB is the accountant’s report on an entity’s own international transactions, due on 31 October. Form 3CEAA is the group-level master file.