Transfer Pricing Compliance Calendar: Due Dates, Forms & Penalties for FY 2025-26 and Tax Year 2026-27

India's transfer pricing framework imposes a structured set of obligations on entities engaged in international transactions and specified domestic transactions (SDTs). With the impending rollout of the new Income-tax Rules, 2026 effective from 1 April 2026, companies and their advisors must navigate a dual-regime landscape — the legacy rules governing FY 2025-26 and the incoming framework applicable from Tax Year 2026-27 onwards. This comprehensive guide consolidates all critical compliance deadlines, applicable thresholds, form references, and penalty consequences to assist assessees in staying fully compliant.

Overview of the Regulatory Transition

The Income-tax Rules, 1962, which have historically governed transfer pricing compliance in India, will continue to apply for FY 2025-26 (AY 2026-27) and all earlier periods. However, from Tax Year 2026-27 (AY 2027-28), the newly notified Income-tax Rules, 2026 will take effect, bringing with them a fresh set of renamed and restructured forms.

Important: The transition does not create any gap in compliance obligations. Assessees must continue to discharge all existing duties under the old rules for FY 2025-26 while simultaneously preparing for the new regime applicable from Tax Year 2026-27 onward.

A notable feature of the new regime is the introduction of a Block Assessment Scheme and graded late fees for delayed filing of accountant's reports, replacing the earlier flat penalty structure in certain cases.

1. Annual Transfer Pricing Documentation (Local File)

Applicability Threshold

Maintaining contemporaneous transfer pricing documentation, commonly referred to as the Local File, is mandatory for assessees whose:

  • International transactions exceed INR 1 Crore in aggregate during the financial year, or
  • Specified Domestic Transactions (SDTs) exceed INR 20 Crore in aggregate

Due Date

The Local File documentation must be prepared and maintained on or before 31 October following the close of the relevant financial year. For FY 2025-26, the deadline falls on 31 October 2026.

Note: There is no prescribed form for this documentation — it is a records-maintenance obligation, not a filing requirement. However, the documentation must be available for production if called upon by the Assessing Officer.

Penalty for Non-Compliance

Regime Penalty Provision Quantum
Income Tax Act, 1961 Section 271AA(1) 2% of the value of each international transaction or SDT
Income Tax Act, 2025 Section 442(1) 2% of the value of each international transaction or SDT

2. Accountant's Report — Form 3CEB / Form 48

Applicability

Every assessee who has entered into any international transaction (with no minimum threshold) or SDTs exceeding INR 20 Crore must obtain and furnish an accountant's report certifying that the arm's length price has been determined in accordance with the prescribed methods.

  • Form applicable for FY 2025-26: Form 3CEB
  • Form applicable from Tax Year 2026-27: Form 48

Due Date

The accountant's report must be filed on or before 31 October following the end of the financial year.

Penalty Structure

This is one of the areas where the new Income-tax Act, 2025 introduces a significant change — replacing the flat penalty with a graded fee mechanism:

**Under Income Tax Act, 1961 — Section 271BA😗*

  • Flat penalty of INR 1,00,000 for failure to furnish the report

**Under Income Tax Act, 2025 — Section 428(d)😗*

  • INR 50,000 for an initial delay not exceeding one month
  • INR 1,00,000 for delays extending beyond one month