Transfer Pricing Assessment where benchmarking meets the Transfer Pricing Officer.
Full representation in TP assessment proceedings under Section 92CA — reply to questionnaires, comparable defence, FAR substantiation, hearing representation, and analysis of the final TP order.
Once a return is picked up for transfer pricing scrutiny, the Assessing Officer refers the international or specified domestic transactions to the Transfer Pricing Officer under Section 92CA. The TPO then runs a separate assessment specifically on the arm's length nature of those transactions.
TP assessment is document-heavy and time-bound. The TPO typically issues detailed questionnaires, asks for fresh comparable sets, challenges the FAR analysis, and may propose adjustments running into crores. Every response goes on record and influences not just the current year but future TP cycles too.
We represent taxpayers in TP assessments end-to-end — drafting replies, defending the TP study, providing additional comparables, and appearing at hearings. The objective is twofold — minimise the adjustment in the current year and lay a defendable record for any onward appeal.
Our Transfer Pricing Assessment Services
TPO Notice Reply
Reply to initial reference and detailed questionnaires from the TPO.
Comparable Defence
Defence of the chosen comparable set against TPO's proposed rejections.
FAR Substantiation
Substantiation of FAR analysis with operational and financial evidence.
Additional Submissions
Additional comparables, adjustments, and judicial precedents submitted.
Hearing Representation
Appearance before the TPO with full factual and legal preparation.
Show-Cause Reply
Reply to show-cause notice proposing TP adjustment.
TP Order Analysis
Detailed analysis of the TPO order with adjustment computation.
Onward Appeal Plan
DRP / CIT(A) appeal strategy based on the TPO order.
Our Approach
Notice Review
Initial TPO reference and questionnaire read against TP study.
Reply Drafting
Substantive reply prepared with annexures and precedents.
Hearings
Oral hearings attended with case-specific evidence.
Show-Cause Stage
Show-cause notice replied to with focused submissions.
Order & Strategy
Final TP order analysed and onward strategy decided.
Why It Matters
Frequently Asked Questions
Assessment of international and specified domestic transactions by the Transfer Pricing Officer.
Section 92CA of the Income-tax Act, on reference by the Assessing Officer.
TP order is generally passed within 21 months from end of the relevant assessment year.
Yes, fresh comparables can be filed, though justification is required.
Yes, the AO is bound by the arm's length price determined by the TPO.
Notice from the TPO?
Get full TP assessment representation — questionnaire replies, comparable defence, and hearing advocacy by Chartered Accountants who handle TP daily.
Defend My TP Case or call +91 9819 000 511