Form No. 48 under Income-tax Act 2025: Detailed Guide to the New Transfer Pricing Certification Framework

1. Overview: Shift from Form 3CEB to Form No. 48

Form No. 48 is the new accountant’s report prescribed under Section 172 of the Income-tax Act, 2025. It replaces Form 3CEB (earlier notified under Section 92E of the Income Tax Act 1961) and is now the core compliance document for reporting:

  • International transactions
  • Deemed international transactions
  • Specified domestic transactions

The form acts as an annual certification that such transactions have been undertaken at arm’s length price. While the underlying transfer pricing principles are largely carried forward from the 1961 law, Form No. 48 introduces a structured, digitally driven, ID-linked architecture intended to standardize and tighten reporting.

Key structural shift:

  • Old regime: Form 3CEB under Section 92E read with Rule 10E of the Income Tax Rules, 1962
  • New regime: Form No. 48 under Section 172 read with Rule 85 of the Income Tax Rules, 2026

The form is designed for online filing with built-in dropdowns, auto-calculation, and cross-linking of transactions via unique IDs, thereby reducing manual data entry but significantly increasing the need for robust internal systems.

2. Legislative Context and Re-alignment of Transfer Pricing Provisions

The Income-tax Act, 2025 is a comprehensive recodification of India’s direct tax law. Provisions earlier housed in Chapter X (Sections 92 to 92F) of the Income Tax Act 1961 have been reorganized under a new chapter dealing with international and specified domestic transactions.

Under this new framework:

  • Transfer pricing report requirement now flows from Section 172
  • Definition of associated enterprise has been moved from Section 92A to Section 162(1)
  • Computation rules for arm’s length price are now housed in Section 165(1)
  • Documentation requirements are linked to Section 171 read with Rule 84(4)

Note: Substantive principles of arm’s length pricing, methods, and documentation remain broadly aligned with the earlier regime; the major change is in form, structure, and reporting granularity.

3. Six-Part Architecture of Form No. 48

Form No. 48 is divided into six logically connected parts:

  1. Part A – Basic particulars of the assessee
  2. Part B – Consolidated transaction values (auto-populated)
  3. Part C – International and deemed international transactions
  4. Part D – Specified domestic transactions (SDT)
  5. Part E – Determination of arm’s length price (ALP)
  6. Part F – Documentation and related certifications

Snapshot of Each Part

  • Part A – Assessee Particulars
    Captures legal identity and basic details: full name, address (with PIN, State, country), PAN, etc.

  • Part B – Aggregate Amounts (Auto-populated)
    Presents a high-level matrix of totals under:

    • International transactions
    • Deemed international transactions
    • Specified domestic transactions
      bifurcated into amounts received and amounts paid.

    The form architecture explicitly states this section will be auto filled from Parts C and D, thereby enforcing internal consistency and reducing reconciliation mismatch.

  • Part C – International & Deemed International Transactions
    This is the core schedule for cross-border dealings and contains:

    • List of associated enterprises with unique AE IDs
    • List of persons for deemed international transactions with unique Person IDs
    • Transaction-wise details mapped through Transaction IDs
    • APA coverage details where applicable

  • Part D – Specified Domestic Transactions (SDT)
    Mirrors Part C but for domestic related-party dealings governed under Section 162(2) and other relevant provisions.

  • Part E – Determination of Arm’s Length Price
    Captures method selection, comparables analysis, aggregation decisions, and computation of ALP and corresponding adjustments for each transaction or group of transactions.

  • Part F – Documentation Certification
    Activated only upon crossing materiality thresholds. Records compliance with Section 171 documentation obligations and proviso to Rule 84(4).

4. Part A and Part B: Identity and High-Level Financial Summary

Part A – Particulars of Assessee

This section is straightforward and foundational. It identifies the assessee for whom the report is being prepared, and typically includes:

  • Full legal name of the assessee
  • Registered address and contact details
  • PAN and jurisdictional details as required by the form

Part B – Aggregate Transaction Values (System-Generated)

Part B is a summarized matrix that displays aggregate values of:

  • International transactions
  • Deemed international transactions
  • Specified domestic transactions

for both amounts received and amounts paid.

The values in Part B are not entered manually. They are auto-computed from the detailed line items reported in:

  • Part C (international and deemed international transactions)
  • Part D (specified domestic transactions)

Practical impact:
Assessees must ensure that transaction-wise inputs are accurate and complete because Part B totals will be generated from those underlying entries, and any inconsistency will be immediately apparent to the certifying accountant and tax authority.

5. Part C: International and Deemed International Transactions

Part C is the most detailed component of Form No. 48 for cross-border dealings.

5.1 AE Master List – Row 5

Every associated enterprise is assigned a unique AE ID (for example, AE-1, AE-2, AE-3, etc.). For each AE, the assessee must disclose:

  • Name and full address
  • Country/territory of tax residence
  • PAN/TIN or any other unique identification number as applicable
  • Relationship code under Section 162(1) (to be selected from a dropdown list of 14 specific categories corresponding to 162(1)(a)(i) through 162(1)(l))

This replaces the earlier disclosure under Section 92A in Form 3CEB. The substance of the associated enterprise definition is largely identical, but the new Act codifies all 14 relationship types explicitly in the instructions to Form No. 48.

5.2 Persons Involved in Deemed International Transactions – Row 6

For transactions that are considered international by virtue of prior arrangements involving third parties (i.e., deemed international transactions), the assessee must separately identify such persons using Person IDs (P-1, P-2, etc.).

Details to be furnished include name, address, and other identifying particulars, segregating these from the AE list for clarity and accurate classification.

5.3 Transaction-Level Reporting – Row 7

Each individual international or deemed international transaction is captured using a Transaction ID (e.g., T-1, T-2, T-3, etc.).