Short answer: a private company in India wholly owned by a foreign parent files with four regulators on four clocks — the Registrar of Companies, the Reserve Bank of India, the income tax department and the GST network — plus the payroll authorities every month. The dates that decide the year are the AGM by 30 September, Form 3CEB and the tax audit by 31 October 2026, the return by 30 November 2026, the FLA return by 15 July and GSTR-9 by 31 December. This year also runs on two Income-tax Acts at once, and the calendar below shows which filing belongs to which.
The Income-tax Act 2025 took effect on 1 April 2026. It governs tax year 2026-27 — the income being earned now, and the TDS and advance tax paid on it. But the big annual filings made between April 2026 and March 2027 report on FY 2025-26, which the 1961 Act still governs.
| Filed in FY 2026-27, reporting on | Act | Forms |
|---|
| FY 2025-26 — transfer pricing report, tax audit, return, SFT, Q4 TDS statements | 1961 Act | 3CEB, 3CA/3CD, ITR-6, 61A, 24Q/26Q/27Q |
| Tax year 2026-27 — TDS deposits and statements, advance tax | 2025 Act | 138 (salary), 140 (resident non-salary), 144 (non-resident) |
The practical point: a team that switches every form to the new numbers on 1 April files the FY 2025-26 transfer pricing report on the wrong form. Form 3CEB is still the form this October. Form 48, its replacement under Section 172 of the 2025 Act, first applies to the report for tax year 2026-27, due in 2027. The detail is in the transfer pricing filings a captive makes.
Most foreign parents close on 31 December. An Indian company closes on 31 March. Section 2(41) of the Companies Act allows a subsidiary of a company incorporated outside India to apply to the National Company Law Tribunal for a different financial year where it must follow one for consolidation abroad — but income tax has no equivalent. The tax year is April to March regardless, so the tax audit and return are always prepared on April-to-March figures.
In practice, then, most subsidiaries run two closes:
- December — a reporting pack in the parent's format (IFRS or US GAAP), on the parent's timetable, often reviewed by the group auditor
- March — the statutory accounts under Indian standards, audited, adopted at the AGM by 30 September, and the base for every Indian filing that follows
Neither replaces the other. How to schedule one set of audit fieldwork to serve both is covered in the statutory audit and the group reporting pack.
These recur and are left out of the monthly tables below.
| Due | Filing | Regime |
|---|
| 7th | TDS deducted in the previous month deposited (March deductions: 30 April) | Income tax |
| 11th | GSTR-1, outward supplies, for the previous month | GST |
| 15th | Provident Fund (PF) and Employees' State Insurance (ESI) contributions for the previous month | Payroll |
| 20th | GSTR-3B, summary return and tax payment, including reverse charge on services from the parent | GST |
| 20th | Professional tax deducted from salaries (Karnataka; other states differ) | Payroll |
| 7 calendar days after month-end | Form ECB-2, only for a month in which an external commercial borrowing was drawn or serviced | FEMA |
ECB-2 changed this year. Until the 2026 amendment to the FEMA borrowing and lending regulations it was a monthly return within seven working days whether or not anything happened; it is now filed for months with a drawdown or debt servicing, within seven calendar days. Whether a loan from the parent should be an ECB at all is in loans from the foreign parent.
| Date | Filing or action | Regime |
|---|
| 30 Apr | TDS on March 2026 payments deposited — 1961 Act, old challans | Income tax |
| 30 Apr | MSME Form I for October 2025 to March 2026, where dues to micro or small suppliers are outstanding beyond 45 days | Companies Act |
| 30 Apr | Professional tax on the company's own enrolment (Karnataka) | Payroll |
| May | Board meeting — year-end review; audit timetable fixed | Companies Act |
| 31 May | TDS statements for January to March 2026 — Forms 24Q, 26Q, 27Q | Income tax |
| 31 May | Statement of Financial Transactions, Form 61A, where the company received ₹10 lakh or more for shares in FY 2025-26 | Income tax |
| 15 Jun | Advance tax, first instalment — 15% of the tax year 2026-27 liability | Income tax |
| 15 Jun | Form 16 to employees for FY 2025-26 | Income tax |
| 30 Jun | DPT-3, return of deposits and of loans that are not deposits (a loan from the parent is reported here) | Companies Act |
| 30 Jun | DIR-3 KYC Web — only for directors whose three-yearly filing falls due in 2026 | Companies Act |
| 15 Jul | FLA return — foreign liabilities and assets as at 31 March 2026 | FEMA |
| 31 Jul | TDS statements, April to June 2026 — first quarter on Forms 138, 140 and 144 | Income tax |
| Aug | Board meeting — adopt audited accounts, board's report, notice of AGM | Companies Act |
| 15 Sep | Advance tax, second instalment — cumulative 45% | Income tax |
| 30 Sep | Annual general meeting (AGM) — latest date | Companies Act |
The FLA return can be filed on unaudited figures if the audit is not finished, and revised once it is. It is due every year while the foreign investment exists — the recurrence most companies miss, as the FEMA filings post explains.
An AGM can be held by video conference: MCA General Circular 03/2025 continued that facility until further orders, but expressly did not extend the 30 September deadline.
| Date | Filing or action | Regime |
|---|
| 15 Oct | ADT-1, where the auditor was appointed at a 30 September AGM | Companies Act |
| 30 Oct | AOC-4 (or AOC-4 XBRL above the XBRL thresholds) — financial statements, within 30 days of the AGM | Companies Act |
| 31 Oct | Form 3CEB — transfer pricing report, FY 2025-26, s.92E of the 1961 Act | Income tax |
| 31 Oct | Tax audit report, Forms 3CA and 3CD, FY 2025-26 — 31 October because s.92E applies | Income tax |
| 31 Oct | Form 3CEAB, only if one Indian group entity is designated to file the Master File | Income tax |
| 31 Oct | MSME Form I for April to September 2026 | Companies Act |
| 31 Oct | TDS statements, July to September 2026 | Income tax |
| Nov | Board meeting — half-year review | Companies Act |
| 29 Nov | MGT-7 annual return, within 60 days of the AGM | Companies Act |
| 30 Nov | Return of income, FY 2025-26, ITR-6 — the date for companies to which s.92E applies | Income tax |
| 30 Nov | Master File, Form 3CEAA — Part A for every group entity, the full form only above the thresholds | Income tax |
| 15 Dec | Advance tax, third instalment — cumulative 75% | Income tax |
| 31 Dec | GSTR-9 annual return, and GSTR-9C reconciliation above ₹5 crore turnover, FY 2025-26 | GST |
| 31 Dec | Annual Performance Report — only if the Indian company itself has an overseas investment | FEMA |
| Jan | Group reporting pack for the parent's 31 December close | Group |
| 15 Jan | Labour Welfare Fund contributions for calendar year 2026 (Karnataka) | Payroll |
| 31 Jan | TDS statements, October to December 2026 | Income tax |
| Feb | Board meeting — third-quarter review, budget, audit planning | Companies Act |
| 15 Mar | Advance tax, fourth instalment — 100% | Income tax |
| 31 Mar | GST Letter of Undertaking for FY 2027-28, for zero-rated exports of services to the parent | GST |
Four board meetings, spaced as above, keep every gap under the 120-day limit in Section 173. A subsidiary can never use the small-company relaxation, because Section 2(85) excludes holding and subsidiary companies from that definition.
AOC-4 and MGT-7 are computed from the AGM date: an earlier AGM brings both forward. Late filing costs ₹100 a day per form — the mechanics are in the annual ROC filings.
Two conditional items are not in the table. CSR applies where net worth reaches ₹500 crore, turnover ₹1,000 crore or net profit ₹5 crore, and brings Form CSR-2 with AOC-4. Country-by-country reporting applies only to groups with consolidated revenue of ₹6,400 crore or more; for a parent whose year ended 31 December 2025, the Indian entity's notification falls two months before the parent's report is due, which works out to 31 October 2026 — confirm whether the portal takes Form 3CEAC or its new-Act equivalent, Form 58, for that year.
Treat these as the statutory dates, not promises:
- Tax audit, Form 3CEB and the return. As at 23 September 2026 no extension has been notified for FY 2025-26, although professional bodies have asked for one. Watch the detail when it comes: in 2025 the CBDT extended the audit and return dates for ordinary audit cases but expressly left Form 3CEB at 31 October. An extension for other companies is not an extension for a subsidiary with transfer pricing.
- ROC forms. The MCA extends AOC-4 and MGT-7 dates without additional fees occasionally, usually close to the deadline, and occasionally runs a one-off settlement scheme. Neither can be planned around.
- GSTR-9. Extended in some years, not in others.
FEMA dates, by contrast, are almost never extended. The FLA return is due on 15 July every year.
| Trigger | Filing | Within |
|---|
| Shares allotted | PAS-3 (ROC) and FC-GPR (RBI, through the authorised dealer (AD) bank) | 30 days of allotment |
| Share subscription money received from abroad | Allot the shares, or refund the money | 60 days of receipt |
| Shares transferred between a resident and a non-resident | FC-TRS | 60 days of transfer or payment, whichever is earlier |
| Authorised capital increased | SH-7 | 30 days |
| Director appointed or resigns | DIR-12 | 30 days |
| Director's mobile, email or address changes | DIR-3 KYC Web | 30 days |
| Declaration received from a significant beneficial owner | BEN-2 | 30 days of receipt |
| Declaration from a nominee holding shares for the parent | MGT-6 | 30 days of receipt |
| Charge created on assets | CHG-1 | 30 days |
| Loan from the parent structured as an ECB | Form ECB (loan registration number) before the first drawdown | Before drawdown |
| Downstream investment by the subsidiary into another Indian company | Form DI | 30 days of allotment |
| Payment to the parent — fees, dividend, interest | Tax deducted under s.393 of the 2025 Act; Form 145, and Form 146 where required, before remitting | Before the remittance |
| Change in GST registration details | REG-14 amendment | 15 days |
The two that surprise foreign parents are BEN-2 — the Indian company must identify the individuals at the top of the parent's chain, set out in significant beneficial owners of a foreign parent — and FC-TRS, which arises on a share sale even though no money reaches the company.
The downloadable calendar below lists every date on this page in one spreadsheet, April 2026 to March 2027, with an event-based section. Each row carries the regime, the form, who it applies to, and two blank columns — Owner and Done — for the company to fill.
The Owner column is the one that matters. Most missed filings in a foreign-owned subsidiary are not missed through ignorance; they sit between the parent's finance team, an Indian accountant and a payroll provider, each assuming another has them.
This calendar sets out the statutory dates for a wholly foreign-owned private company in India for FY 2026-27, as at 23 September 2026. It is not advice on a particular company: whether a conditional filing applies — MSME Form I, CSR, the Master File, country-by-country reporting, ECB reporting — depends on the company's own figures and transactions. The CBDT, the MCA and the GST Council extend dates by circular, and professional tax and labour welfare fund rules differ from state to state; the Karnataka dates given here are an example. Confirm each date against the current notification before relying on it.