Maintaining the 'Master File' is governed by the Section 92D(4) read with rule 10DA
The Master file is mandated where the entity exceeds certain prescribed parameters, as under,
1. Where the consolidated group revenue exceeds INR 500 crores. and
2. aggregate value of the international transaction, during the accounting year as per books of accounts exceeds 50 crore rupees, or purchase/sale/transfer/lease/use of intangible property during the accounting year as per books of accounts exceeds 10 crore rupees.
The master file should be maintained and furnished to the Director Genera of the Income-Tax (Risk Assessment) [DGIT(RA)]
The Master File shall be submitted as Form No. 3CEAA to the DGIT(RA) due date for which is the due date of furnishing the income tax return. (Mostly 30th November)
The Master file has Part A an Part B.
Part A shall be filled by every group entity of the International group irrelevant whether the above parameters are satisfied or not (i.e. either one or both of the above parameters are met but not both).
Part B shall be filed by the constituent entity where the parameters set above are met.
Where there are more than one constituent entity, one entity shall be designated to furnish the master file and such designation shall be intimated to the to the DGIT(RA) in form 3CEAB. This intimation shall be made atleast 30 days before the due date of filing the Master File.
(6) The Principal Director General of Income-tax (Systems) or Director General of Income-tax (Systems), , shall specify the procedure for electronic filing of Form No. 3CEAA and Form No. 3CEAB and shall also be responsible for evolving and implementing appropriate security, archival and retrieval policies in relation to the information furnished.
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