Transfer Pricing Laws Sections 92 to 92F — India's arm's length code.
Detailed advisory on Indian transfer pricing law — Sections 92 to 92F of the Income-tax Act, Rules 10A to 10THD, and the procedural framework for international and specified domestic transactions.
Indian transfer pricing law sits in Sections 92 to 92F of the Income-tax Act, 1961, supported by Rules 10A to 10THD. Together they require that every international transaction and every specified domestic transaction between associated enterprises be priced at arm's length, with documented justification.
The law covers a wide net — direct and indirect ownership, common control, key personnel overlap, and dependency relationships can all create associated enterprise status. Once that bridge is crossed, every cross-border or specified domestic dealing between the parties comes under the TP microscope.
We help groups understand exactly where the law touches them, what filings it triggers (Form 3CEB, Master File Form 3CEAA, CbCR Form 3CEAD), and how to build compliance from the ground up — starting with associated enterprise mapping and transaction inventory.
Our Transfer Pricing Laws Services
Section 92 to 92F Mapping
Mapping of the entity's facts to the relevant transfer pricing provisions.
Associated Enterprise Test
Application of Section 92A to identify all associated enterprises.
International Transactions
Section 92B coverage of cross-border transactions with AEs.
Specified Domestic Transactions
Section 92BA review for specified domestic transaction triggers.
ALP Methods
Choice of CUP, RPM, CPM, PSM, or TNMM under Section 92C and Rule 10B.
Form 3CEB Filing
Section 92E audit report by an Accountant in Form 3CEB.
Master File & CbCR
Section 286 / Rule 10DA / 10DB Master File and CbC reporting.
Penalties Advisory
Section 271AA, 271BA, and 271G penalty exposure review.
Our Approach
Entity Map
Group structure mapped to identify all associated enterprises.
Transaction Catalogue
Every international and specified domestic transaction listed.
Law Application
Provisions and rules applicable to each transaction identified.
Compliance Plan
Form 3CEB, Master File, CbCR, and documentation timeline drawn.
Implementation
Filings made, documentation maintained, and reviews scheduled.
Why It Matters
Frequently Asked Questions
Pricing of transactions between associated enterprises at arm's length under the Income-tax Act.
Sections 92 to 92F of the Income-tax Act, 1961.
An enterprise that participates directly or indirectly in management, control, or capital of another.
An accountant's report on international and specified domestic transactions, filed annually.
Only to specified domestic transactions defined under Section 92BA of the Act.
Need Clarity on TP Law?
Get a clear map of which transfer pricing provisions apply to your group — and a compliance plan that closes every Section 92 to 92F obligation.
Map My TP Obligations or call +91 9819 000 511