A dedicated practice for entities with international transactions or specified domestic transactions with associated enterprises.
Indian transfer pricing law, governed by Sections 92 to 92F of the Income-tax statute and the corresponding rules, requires every taxpayer entering into such transactions to determine arm's-length pricing, maintain contemporaneous documentation and obtain an accountant's report in Form 3CEB. Inadequate documentation invites disallowance, primary and secondary adjustments, and steep penalties.
We handle the full engagement — from functional, asset and risk (FAR) analysis through method selection, benchmarking on accepted databases, and preparation of the Local file, Master file and Country-by-Country report where applicable. The firm also represents clients before the Transfer Pricing Officer, the Dispute Resolution Panel and in subsequent appellate forums, and advises on Advance Pricing Agreement (APA) applications.