India · Service
Documentation, benchmarking and defence for related-party transactions, built to the standard an assessing officer cannot easily dislodge.
Related-party transactions draw scrutiny precisely because they are easy to adjust. We prepare arm’s-length documentation, run defensible benchmarking studies and represent the position through assessment, so that intercompany pricing is supported by analysis, not assertion.
Local file, master file and the prescribed Indian TP study, prepared to survive scrutiny.
Comparable selection and arm’s-length-range analysis using recognised databases.
TNMM, CUP, cost-plus and others applied to the facts, with reasons documented.
Accountant report certification and filing for international and specified domestic transactions.
Defence before the Transfer Pricing Officer and through assessment and appeal.
Advance-pricing-agreement support and forward planning for recurring flows.
We identify every associated-enterprise transaction and its character.
We run the comparability and arm’s-length analysis and select the method.
We prepare the study, master file and accountant's report (Form 3CEB, now Form 48) to filing standard.
We represent the position before the TPO and on appeal if adjusted.
We write the documentation knowing we may have to argue it, so it is built to be argued.
International transactions with associated enterprises must be at arm’s length whatever their size. From 1 April 2026 the rules are in sections 161 to 173 of the Income-tax Act, 2025; transactions up to 31 March 2026 remain under sections 92 to 92F of the 1961 Act.
| Obligation | Trigger | Timing |
|---|---|---|
| Transfer pricing documentation | International transactions above Rs 1 crore in aggregate | Contemporaneous; ready by the report date |
| Accountant’s report: Form 48 (formerly Form 3CEB) | Any international or specified domestic transaction | One month before the return due date, usually 31 October |
| Master file | Group revenue above Rs 500 crore and international transactions above Rs 50 crore, or intangibles above Rs 10 crore | With the return timeline |
| Country-by-country report | Group revenue of Rs 6,400 crore or more | Within 12 months of the group’s year end |
Thresholds are as prescribed in the rules for financial year 2025-26; check the Income-tax Rules, 2026 for later years.
For a worked India-UAE example, see transfer pricing between India and the UAE.
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Read the guide →Income-tax Act 2025Income-tax Act 2025 Section Mapping for Cross-Border Work: Old vs New Sections and FormsThe 1961-to-2025 section and form map a cross-border practitioner needs: non-resident TDS, lower deduction, treaty relief, transfer pricing, reside...
Read the guide →Book a consultation to scope your documentation, benchmarking and Form 3CEB obligations.
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