Form 3CEB, clause by clause — and the whole year-end TP calendar
The accountant's report under section 92E the way the Guidance Note wants it signed. For each of the 26 clauses of Form 3CEB — Part A particulars, Part B international transactions (AEs, tangibles, intangibles, services, loans, guarantees, securities, cost contribution, restructuring, deemed transactions), Part C specified domestic transactions — the desk shows what the form asks, the procedures, evidence, thresholds and pitfalls the Guidance Note prescribes, and an AI clause guide for the matter in hand. The year-end programme turns the client's profile into the 3CEB / TP study / Master File / CbCR calendar with due dates, consequences and checklists. Upload a prepared 3CEB or a TP study and get a clause-by-clause or Rule 10D gap review before you sign.
The 3CEB programme on the client's Tally books
The TaxCorp Tally Bridge pull that serves the tax audit serves the 3CEB too: no second extract. Open the programme, pick the snapshot, confirm the AEs, run the procedures.
AE register
Candidates from the ledger masters — foreign country or currency, entity suffix, group-name tokens, s.195 TDS, no PAN — confirmed with the s.92A relationship and the ledgers each AE appears under.
As per books, per clause
Every AE posting classified from the vouchers into clauses 11A/11B/11C, 12, 13, 14, 15, 16, 17, 18, 19 — quantities from stock items, settlements excluded, Part A aggregates and the s.195 / import-RCM reconciliations.
Loans and s.94B
Loan movement per AE ledger, interest, implied rate, and the interest-limitation test against 30% of EBITDA from the P&L.
ALP from the study
Upload the TP study: the AI reads out every benchmarked class — AE, nature, ALP amount, method, PLI — into editable inputs. The arm's length column is never computed from the books.
AI accountant, your instruction
Per clause: the Guidance Note and Handbook text, the digest, the books pack, the register, the ALP inputs, your documents. Verdicts on every row, findings, the clause particulars drafted in the Form's format.
Your decisions, the 3CEB
Include / exclude every row, Report / Nil / N.A. every clause, settle the text. Form 3CEB assembled from your conclusions; engagement letter and MRL; Word, PDF, JSON. Ask the books in between.
How a clause is worked on the desk
The same shape for every clause of Form 3CEB — from the AE list in clause 10 to the SDT catch-all in clause 26. Nothing is concluded for you; everything is prepared for you.
What the form asks
The notified particulars of the clause: per AE, per transaction or class, 'as per books' against 'as computed at arm's length', the method under s.92C(1).
Guidance Note digest
Procedures, evidence to obtain, data from the books, thresholds and pitfalls, digested from the Revised 2026 edition and the Handbook's clause checklists.
The matter in hand
Describe the transaction — the royalty, the management fee, the loan, the restructuring — and the AI applies the clause guidance to it, with draft wording.
Year-end programme
Tick the client's profile: international transactions, SDT, Master File, CbCR, safe harbour, APA. Get the calendar with due dates and consequences and the review checklists.
Review before signing
Upload the prepared 3CEB: clause-by-clause status (OK / Issue / Missing / Verify), cross-clause consistency, qualifications to consider. Upload the TP study: Rule 10D(1) item by item.
Your decision
Every output is a working aid with the Guidance Note reference beside it. The accountant signs; the AI never does.
What is covered
| The report (paras 1-3) | Examination of accounts and records, proper information and documents kept, particulars true and correct; reliance on management, qualifications, who may sign, the engagement letter and the management representation letter. |
|---|---|
| Part A · clauses 1-9 | Name, address, PAN, nature of business, status, previous year, assessment year, aggregate value of international transactions and of specified domestic transactions — and how the aggregates must tie to the clauses. |
| Part B · clauses 10-20 | AE list and the s.92A relationships; raw materials, traded goods and other tangibles; intangibles; services; lending and borrowing (with s.94B); guarantees; marketable securities and equity; cost contribution arrangements; business restructuring; any other transaction; deemed international transactions under s.92B(2). |
| Part C · clauses 21-26 | Specified domestic transactions under s.92BA: eligible-unit transfers (ss. 80-IA(8)/(10), 80A(6), 10AA), s.115BAB(6) and s.115BAE(4) transactions, the aggregate threshold, any other SDT. |
| Arm's length price | The methods (CUP, RPM, CPM, PSM, TNMM, other), most appropriate method, comparability and adjustments, the Rule 10CA range and the arithmetic mean, tested party, multiple-year data. |
| Documentation | Rule 10D(1) items (a) to (m), supporting documents, contemporaneous data, retention; the TP study's corporate overview, industry analysis, FAR, economic analysis; the Handbook's year-end and transaction-wise review checklists. |
| Master File and CbCR | Forms 3CEAA (Parts A and B) and 3CEAB, the thresholds and the India-specific items; Forms 3CEAC, 3CEAD and 3CEAE, the group revenue threshold, reporting entity, data collection and risk indicators. |
| Penalties | Failure to furnish the report, to maintain or furnish documentation, to furnish Master File or CbC report; under-reporting; reasonable cause. |
Form 3CEB clause desk
Pick any of the 26 clauses (or the report itself). The digest shows what to report, the procedures, the evidence, the thresholds and the pitfalls; the AI clause guide applies it to your transaction and drafts the row.
Year-end TP compliance programme
From the client's profile: the FY calendar for 3CEB, TP documentation, Master File (3CEAA / 3CEAB), CbCR (3CEAC / 3CEAD / 3CEAE), safe harbour and APA, with due dates and consequences, plus the year-end and transaction-wise checklists.
Review a prepared 3CEB
Upload the form (Excel, Word or PDF). Clause-by-clause status with the specific omission or wrong format, cross-clause consistency (AE list vs transactions, Part A aggregates, deemed transactions, SDT nil), and the qualifications to consider.
TP study check
Upload the study and the intercompany agreements. Rule 10D(1) item by item, FAR and characterisation, tested party, method selection, comparables and adjustments, the range, year-end true-up and secondary adjustment exposure.
Penalty exposure
Describe the lapse or the proposed adjustment. The provisions that bite, the amount basis, the defences and what to do now.
Research
AE tests, international and deemed transactions, SDT, methods and the range, documentation, Master File and CbCR thresholds, penalties — every answer cites the Guidance Note chapter, paragraph and page. Open to every member.
Grounded in the ICAI texts
The Guidance Note on Report under Section 92E (Revised 2026, tenth edition, September 2026, with the Act, Rules, Forms, circulars, engagement letter and MRL annexures) and the Handbook on Year-End TP Compliance Checklists (FY 2025-26, Finance Act 2026) are the ground truth. Nothing is answered from memory.
Litigation lives next door
TPO adjustment, DRP, ITAT? International Tax AI carries the transfer pricing case law and the TP adjustment defence template, and now reads the same guidance when the question is a TP one.
Sign the 3CEB the way the Guidance Note wants it signed.
Included with Tax Audit AI for your firm; research is open to every member.