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Transfer Pricing News


​Relaxation of Statutory Timelines Due to Covid-19 Pandemic

The second wave of Covid-19 pandemic was at its peak in India during the period of April to June 2021, which saw record high daily cases and casualties. This situation led to country wide emergency lockdowns and disruption in economic activities. Taking cognizance of the genuine hardships faced by the taxpayers in making various compliances within the prescribed due dates, the Central Board of Direct Taxes issued a Circular No. 9 dated 20 May 2021 to provide relief with respect to extending due dates for certain compliances for FY 2020-21.


In this connection, the due dates of the following annual compliances under transfer pricing are extended as follows by the aforesaid circular.


ParticularsDue Date 

Extended Due Date

Filing of Accountants Report in Form 3CEB

31 October 2021

30 November 2021

Master File in Form 3CEAA

30 November 2021

31 December 2021

Intimation of Master file in Form 3CEAB

31 October 2021

30 November 2021


Additionally, Central Board of Direct Taxes vide Circular No. 12 dated 25 June 2021 also provided relaxation in filing the objections with the Dispute Resolution Panel (‘DRP’) and the Assessing Officer under section 144C of the Income Tax Act, 1961.

Accordingly, in cases if the last date of filing of the objections to the draft assessment order falls after 1 June 2021 or thereafter, then the objections can be filed within 30 days after receipt of order or 31 August 2021, whichever is later.

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