Income-tax Act, 1961Section 92E
- Accountant's report for international or specified domestic transactions
- Due one month before the return due date
- Penalty for failure under 271BA
Applies to FY 2025-26 (AY 2026-27) and earlier years.
IT Act 1961 → 2025 / Section 92E
Transfer pricingSection 92E → Section 172
Transfer pricing accountant's report (Form 3CEB) for international and specified domestic transactions
Section 92E of the old Income-tax Act, 1961 · new section 172 under the Income-tax Act, 2025
New reference Section 172
Income-tax Act, 2025Section 172
- Same requirement, now section 172
- Report due by the specified date in the prescribed form
- Failure now attracts a fee of ₹50,000 (up to one month) / ₹1,00,000 under section 428(d), from 1 April 2026
Applies from tax year 2026-27 (from 1 April 2026).
What changed
Renumbered; the Finance Act 2026 replaced the penalty for not furnishing the report with a fixed fee.
Practice notes
- Arm's length price is defined in section 173(a); methods for computing it are in section 165.
Frequently asked
What is the penalty for not filing Form 3CEB under the new Income Tax Act 2025?
A fee under section 428(d): ₹50,000 for a delay up to one month and ₹1,00,000 thereafter (from 1 April 2026).
What is section 92E called in the new Income-tax Act, 2025?
Section 92E of the Income-tax Act, 1961 corresponds to Section 172 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).
What changed in section 92E under the new Income Tax Act?
Renumbered; the Finance Act 2026 replaced the penalty for not furnishing the report with a fixed fee.
Is section 92E still applicable for FY 2025-26?
Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 92E of the 1961 Act. Section 172 of the 2025 Act applies from tax year 2026-27.