Form 3CEAA, the Master File: who files it, and how | CrossCheckAI

By Nikhil Pathak — Semi Qualified CA · 2026-06-18 · 17 min read

TRANSFER PRICING  /  MASTER FILE  /  SECTION 92D R.W. RULE 10DA

Form 3CEAA, the Master File: who files it, and how

Most of the confusion around the Master File comes down to one question: do you file just Part A, or Part A and Part B? Get that right and the rest is process. This guide walks the whole thing, with numbers.

Updated: [17th June 2026]

If your company sits inside a multinational group, there is a good chance you owe the tax department a Master File. In India it is filed as Form 3CEAA. People assume it is one heavy report that either applies to them or does not. It is actually two parts with two very different triggers, and that split is where most filing mistakes start.

This piece goes through it in order. What the form is, who files which part, the exact numbers that decide it, worked examples you can map to your own figures, the filing steps, the deadlines, the penalties, and the questions people ask most. Every point is tagged with the section or rule behind it.

What the Master File actually is

India runs transfer pricing documentation on three layers. The Master File is the middle one. It is a single group-wide picture of a multinational: where it operates, who owns what, how money and intangibles move around the group, and how the group sets its internal prices.

It comes from the OECD's BEPS project (Base Erosion and Profit Shifting), the global push to stop profits being parked in low-tax places. India brought it in from 31 October 2017 Rule 10DA. In the law itself, the Master File is the report required under section 92D(4), the format is set by Rule 10DA, and it is filed with the prescribed authority under Rule 10DB.

The three tiers, side by side

It helps to place the Master File against its neighbours. The Local File is about your own transactions. The Master File is about the whole group. The Country-by-Country report is about where the group earns and where it pays tax.

Form 3CEAA borrows its core vocabulary from these neighbouring provisions. "Constituent entity", "international group" and "accounting year" all come from section 286(9). "Associated enterprise" comes from section 92A and "international transaction" from section 92B. There is a plain-language cheat-sheet of these near the end.

Part A only, or Part A plus Part B?

This is the one call that decides how much work you are in for, so it is worth slowing down here.

Part A is short. It is identifying information about the assessee and the group, nothing analytical. Every constituent entity of an international group files it. There is no revenue cut-off and no transaction cut-off. Small group, no cross-border dealings, does not matter. You still file Part A Rule 10DA(3).

Part B is the real Master File: the detailed group write-up. You file it only when the group is big enough and transacts enough. Both conditions in Rule 10DA(1) have to be true together.

Decision tree: do I file Part B?

Read it top to bottom. The only route to Part B needs a yes on the revenue test and a yes on the transaction test. Everything else lands on Part A only.

The thresholds, spelled out

Worked examples: four scenarios, run through the test

Numbers make the AND/OR logic obvious. Each example below is a hypothetical group. Map your own figures onto them.

Example 1: revenue gate fails (big transactions, small group)

Group revenue: Rs. 420 cr    Intl transactions: Rs. 80 cr    Intangibles: Rs. 6 cr

Revenue above Rs. 500 cr? No, it is Rs. 420 cr. The revenue gate fails, so you never reach the transaction test. It does not matter that international transactions are Rs. 80 cr.

Verdict: Part A only

Example 2: transactions too low (large group, modest dealings)

Group revenue: Rs. 900 cr    Intl transactions: Rs. 35 cr    Intangibles: Rs. 4 cr

Revenue above Rs. 500 cr? Yes. Now the transaction test: are intl transactions above Rs. 50 cr (no, Rs. 35 cr) or intangibles above Rs. 10 cr (no, Rs. 4 cr)? Neither limb is met, so Part B is not triggered.

Verdict: Part A only

Example 3: the intangibles limb (where the OR earns its keep)

Group revenue: Rs. 1,200 cr    Intl transactions: Rs. 45 cr    Intangibles: Rs. 12 cr

Revenue above Rs. 500 cr? Yes. Transaction test: intl transactions are Rs. 45 cr, under the Rs. 50 cr line. On the first limb alone you would stop. But intangibles are Rs. 12 cr, above Rs. 10 cr, so the OR limb is met. Both conditions are now satisfied.

Verdict: Part A + Part B

Example 4: many Indian entities (one filer for the whole group)

Group revenue: Rs. 2,000 cr    Indian entities that qualify: 3

Thresholds are clearly crossed, so Part B is due. Three Indian constituent entities each qualify. Rather than each filing the same group-level report, the group designates one of them to file for all three. The catch: it must file Form 3CEAB at least 30 days before the 3CEAA due date Rule 10DA(4). Do that, and one filing covers everyone.

Verdict: Part A + Part B, filed once by the designated entity

The filing process, step by step

Filing is a sequence, so here it is as one. Steps 4 onward only matter once you have settled your Part A or Part B position from the tree above.

1.   Confirm you are in scope. Check that you are a constituent entity of an international group as defined in section 286(9). If you are, Part A is already on your plate.

2.   Pull the numbers and run the tests. Get the consolidated group revenue and your international and intangibles transaction totals. Apply the Rs. 500 cr, Rs. 50 cr and Rs. 10 cr tests from Rule 10DA(1).

3.   Lock the Part A or Part A + B decision. Decide before you start compiling. Part B is a much larger document-gathering job, and you do not want to discover halfway that it applies.

4.   If several Indian entities qualify, pick one filer. The group can name a single Indian constituent entity to file for everyone, but only after it files Form 3CEAB at least 30 days before the 3CEAA due date Rule 10DA(4).

5.   Compile the contents. Assemble Part A always, and if triggered, the fourteen Part B items: entity lists, ownership chart, business and intangibles descriptions, financing details, and the consolidated accounts.

6.   Get it verified by the right person. The form has to be signed by the person competent to verify the return of income under section 140. For a company that is usually the managing director.

7.   File electronically, on time. Furnish Form 3CEAA to the Joint Director on or before the due date for the return under section 139(1) Rule 10DA(2). It goes in online, on the income-tax e-filing portal.

8.   Archive for eight years. Keep the information and documents for eight years from the end of the relevant assessment year Rule 10DA(6).

What goes into Part A

Part A is the easy half. It is identification, not analysis. Here is every field in plain terms.

What goes into Part B

Part B is the substance. It has fourteen items Rule 10DA(1)(a) to (n). They sound heavy, but they group into four themes plus the accounts and any rulings.

Designating one entity, Form 3CEAB

Large groups often have more than one qualifying Indian entity. Instead of each filing the same group-level report, the group can nominate one to do it for all.

The constraint is timing. The designation is intimated to the Joint Director on Form 3CEAB, and it has to reach them 30 days before the Form 3CEAA due date Rule 10DA(4). Miss that window and the shortcut disappears. Each qualifying entity is then back to filing on its own.

Designation flow

9.   Multiple Indian constituent entities qualify to file.

10.The group designates ONE entity to file Form 3CEAA.

11.File Form 3CEAB with the Joint Director, at least 30 days before the 3CEAA due date.

12.The designated entity files Form 3CEAA for all of them.

Dates, retention and signatures

The vocabulary, decoded

Form 3CEAA leans on definitions scattered across the Act. Here they are in one place, in everyday language.

What trips people up

•      Skipping Part A. The most common slip. Being below every threshold does not excuse you. Part A is owed by every constituent entity, full stop Rule 10DA(3).

•      Misreading the AND/OR. Treating all three thresholds as "any one" over-files. Treating them as "all three" under-files. It is revenue and (transactions or intangibles).

•      Missing the 30-day 3CEAB window. If you plan to file through one designated entity but file 3CEAB late, or not at all, the designation fails and every qualifying entity files separately.

•      Using the wrong exchange rate. Group revenue in foreign currency converts at the TT buying rate on the last day of the accounting year, not a year average or book rate Rule 10DA(7).

•      Wrong signatory. The form is invalid if it is not signed by the person competent to verify the return under section 140.

•      Confusing the three tiers. The Local File, the Master File and the CbC report are separate obligations with separate triggers. Clearing one does not clear the others.

The cost of getting it wrong

The penalties sit mainly in section 271AA, with section 271G covering information called for during proceedings.

The fixed fee is rarely the whole story. An incomplete or inaccurate Master File invites a closer look at the group's transfer pricing, and that scrutiny usually costs more than the Rs. 5 lakh itself.

FAQ: questions people actually ask

Who has to file Form 3CEAA?

Every constituent entity of an international group files Part A. Part B is added only when the group's consolidated revenue is above Rs. 500 crore and either international transactions are above Rs. 50 crore or intangibles transactions are above Rs. 10 crore (Rule 10DA).

Do I file Part A even with no international transactions?

Yes. Part A has no threshold. If you are a constituent entity of an international group, you file it regardless of transaction value or income (Rule 10DA(3)).

What is the due date for Form 3CEAA?

On or before the due date for filing your income-tax return under section 139(1) for the relevant year (Rule 10DA(2)).

Can one entity file for the whole Indian group?

Yes, if the group designates one Indian constituent entity and files Form 3CEAB with the Joint Director at least 30 days before the 3CEAA due date (Rule 10DA(4)).

What is the penalty for not filing?

Rs. 5,00,000 for failing to furnish the Master File by the due date under section 271AA(2), plus possible scrutiny of the group's transfer pricing.

How is the Rs. 500 crore tested for a foreign group?

Consolidated group revenue in foreign currency is converted at the telegraphic-transfer buying rate on the last day of the accounting year (Rule 10DA(7)).

How long do I keep the records?

Eight years from the end of the relevant assessment year (Rule 10DA(6)).

What is the difference between 3CEAA, 3CEAB and 3CEAD?

3CEAA is the Master File itself. 3CEAB is the intimation that designates one Indian entity to file it. 3CEAD is the separate Country-by-Country report under section 286.

Before you file: checklist

•      Confirmed the entity is a constituent of an international group (s.286(9)).

•      Part A information assembled: assessee, group, and all Indian constituent entities.

•      Consolidated group revenue obtained and tested against Rs. 500 cr.

•      International transactions tested against Rs. 50 cr, intangibles against Rs. 10 cr.

•      Part A-only versus Part A + B decision documented.

•      If multiple Indian entities qualify: filer designated and Form 3CEAB filed 30 days early.

•      Part B's fourteen items compiled where triggered, including consolidated financials.

•      Foreign-currency revenue converted at the TT buying rate on the last day of the year.

•      Form verified by the person competent under section 140.

•      Filed with the Joint Director on or before the section 139(1) due date.

•      Records archived for the eight-year retention period.

References

13.Form 3CEAA. Master File, the report under section 92D(4), prescribed by Rule 10DA.

14.Rule 10DA. Maintenance and furnishing of Master File information: thresholds, contents, due dates, retention and the forex rule.

15.Rule 10D. Information and documents (the Local File) to be kept under section 92D.

16.Section 92D. Maintenance, keeping and furnishing of information and documents.

17.Section 92A. Meaning of "associated enterprise".

18.Section 92B. Meaning of "international transaction".

19.Section 92C. Computation of arm's length price.

20.Section 92F. Definitions, including "arm's length price" and "enterprise".

21.Section 286. Country-by-country reporting and the section 286(9) definitions used by the Master File.

22.Sections 90 and 90A. Double taxation relief agreements, the "agreement" framework referenced by section 286.

23.Sections 271AA and 271G. Penalties for documentation and furnishing failures.

Note. This guide is general information based on the Income-tax Act, 1961 and the Income-tax Rules, 1962 as they stand. It is not legal or tax advice. Thresholds, forms and procedures change, so a filing should be confirmed against the current statute, rules and e-filing utility for the relevant assessment year. For a specific situation, consult a qualified professional.