Form 3CEAA - Due Date, Applicability, Requirement, And How To File Form 3CEAA Online

India introduced Country-by-Country reporting requirements to monitor international transactions with non-residents, as well as certain specified domestic transactions. All entities are required to submit transaction reports in Form 3CEAA, in accordance with the compliance provisions outlined in Section 92D of the Income Tax Act. This section governs transfer pricing activities and should be considered in conjunction with Rule 10(D) of the Income Tax Act. 

What is Form 3CEAA?

Form 3CEAA under the Income Tax Act is commonly referred to as the Master File. It contains details of all international transactions undertaken by an entity, along with certain specified domestic transactions. The requirement to maintain this Master File was introduced by the government in 2017.

Form 3CEAA is a mandatory document for any person engaged in international transactions or specified domestic transactions, as per the Income Tax Act. It must be furnished in accordance with the provisions of Section 92D. However, this form should not be considered in isolation, as Rule 10D outlines the details of other supporting documents that must also be maintained and submitted.

Form 3CEAA Applicability

Form 3CEAA mainly has two parts, i.e. Part A and Part B. Both parts apply to entities when they meet different conditions. Let us take a look at both these parts in detail:

Part A

Part A of the Master File contains fundamental information about the international group engaged in transfer pricing activities. It includes details such as the name of the group, the entities that form part of it, and specific information for each entity—like their PAN, registered address, and other relevant particulars. 

Part A of Form 3CEAA must be filed by every entity that has entered into any international transaction, regardless of the transaction's value or threshold. This requirement enables the Indian government to maintain a comprehensive record of such transactions.

Part B

Part B of the Form 3CEAA does not apply to everyone. It is to provide in-depth details about the international group and all transactions undertaken. Only the following entities who meet the given two conditions shall file this form:

• The consolidated group revenue for the preceding accounting year exceeds Rs.500 crore.
• The total value of the international transactions conducted has exceeded Rs.50 crore for the present accounting year, or if there have been any international intangible property-related transactions, the value of such transactions exceeds Rs.10 crore.

Form 3CEAA Due Date

The due date for filing this form shall be the same as the due date for filing your income tax returns as per Section 139(1)  i.e. November 30^th of the said Assessment year. Only for the year of introduction, i.e. FY 16-17, this due date was 31st March 2018. 

However, for all following years, the due date of Form 3CEAA is the same as the date of filing the income tax return for such entities. 

Form 3CEAA Requirements

Form 3CEAA has two parts; hence, both parts of this form require different information. Here is an overview:

Part A

Since Part A is for every person who meets the eligibility criteria of Section 92D, it covers mostly all basic information needed for record keeping. Any person filing this return shall have to furnish the following details:

• Name
• Address
• PAN or Aadhaar
• Name and address of the international group

Part B

This is a more elaborate section that is only for certain assessees that we have already discussed. Some of the information to be furnished in Part B includes:

• List of all entities part of the international group along with their address. 
• The legal status of the constituent entity and a complete detail on the ownership structure of the international group. 
• A description in writing explaining business of the international group during a particular accounting year. 
• The nature of their business.
• The main drivers for profit of the group.
• Description giving details of supply chain for the five largest services or products of the international group. 

In short, Part B of the form requires an assessee to fill in all details that give a complete and true idea of the international group, as well as the constituent assessees. 

Form 3CEAA Purpose

Whenever an entity enters into an international or specified domestic transaction, the Government of India is required to document all those transactions. This measure helps monitor Base Erosion and Profit Shifting (BEPS) and ensures that international groups conduct transactions at arm’s length, as they would with unrelated parties. In line with the compliance requirements under Section 92D of the Income Tax Act, entities are obligated to maintain both a Country-by-Country Report and a Master File in Form 3CEAA.

Who is Required to File Form 3CEAA?

Every person who enters an international transaction or any specified domestic transaction with an international group has to file Form 3CEAA. This form has two parts, where Part A is for any person who triggers this requirement. Part B, however, is only for specified persons who fulfil any of the following two conditions:

• Group revenue for the preceding accounting year, when consolidated, exceeds Rs.500 crore.
• Either of these two:
  • The total value of the international transactions conducted has exceeded Rs.50 crore for the present accounting year.
  • If there have been any international intangible property-related transactions, the value of such transactions exceeds Rs.10 crore.

Penalty for non-filing of Form 3CEAA

 According to Section 271GB of the Act, the applicable penalties include: 

• A penalty of ₹5,000 per day will be imposed if the form remains unsubmitted for a period of one month.
• A penalty of ₹15,000 per day will be imposed if the form remains unsubmitted for more than one month. 
• If the form is not submitted even after the penalty has been levied, as per (i) or (ii) above, a further penalty of ₹50,000 per day of default will be charged, starting from the date the penalty order is served.

How To File Form 3CEAA Online?

The following are the steps to file Form 3CEAA online:

Step 1: Login on the e-filing portal

 Step 2: On the dashboard, click ‘e-File’ > ‘Income tax forms’ > ‘File Income Tax Forms’

Step 3: Scroll down to select Form 3CEAA. Alternatively, enter Form 3CEAA in the search box. Click on ‘File now’ button to proceed.

Step 4: Select the Assessment Year for which you are filing the return. For eg: If you are filing taxes for the income earned in FY 2023-24, then select AY 2024-25. 

Step 5: After checking the documents required for filing the form click on 'Let's Get Started'.

Step 6: Fill all the necessary details and click on ‘Preview’

Step 7: After reviewing all the information, ‘Proceed’ to e-verify'. You can e-verify either through:

• Aadhaar OTP
• Digital Signature Certificate (DSC)
• Electronic Verification Code (EVC)

Step 8: After verification Click on 'Yes' to submit the Form.

Step 9: After successful e-Verification, a success message is displayed along with a Transaction ID and an Acknowledgement Receipt Number. Please keep a note of the Transaction ID and Acknowledgement number for future reference. You can also download the form and locate the acknowledgment number. 
To download the filed form, go to ‘e-File’ → 'Income Tax Forms' → 'View Filed Forms'.