Transfer Pricing Services from policy design to assessment defence.
Full-stack transfer pricing support — policy design, benchmarking, Local File and Master File, Form 3CEB certification, CbCR filing, audit defence, DRP, ITAT representation, and APA support.
Transfer pricing is no longer a year-end checkbox. For multinational groups operating in India, it has become a continuous discipline that runs through policy design, intercompany contracts, accounting, year-end documentation, and tax audits — often spanning multiple jurisdictions.
Our transfer pricing practice covers the full life cycle. We help groups design intercompany policies that survive both Indian and foreign tax scrutiny, run robust benchmarking studies on Indian and global databases, file Form 3CEB and the Master File / CbCR, and defend positions through assessment, DRP, ITAT, and even High Court.
Every engagement is led by a qualified Chartered Accountant with hands-on transfer pricing experience across manufacturing, services, IT/ITeS, e-commerce, pharmaceuticals, and financial services sectors.
Our Transfer Pricing Services Services
TP Planning & Policy
Design of arm's length policies for intercompany transactions.
Benchmarking Study
Comparable analysis using ProwessIQ, Capitaline, Royaltystat, and global databases.
Local File
Local File preparation under Rule 10D covering all AE transactions.
Form 3CEB Certification
Accountant's report under Section 92E filed annually.
Master File & CbCR
Master File (Form 3CEAA) and CbCR (Form 3CEAD) filings.
TP Assessment
Representation before Transfer Pricing Officer in TP audit.
DRP & ITAT
Dispute Resolution Panel and ITAT representation on TP adjustments.
APA Support
Unilateral and bilateral Advance Pricing Agreement support.
Our Approach
Scoping
Group structure, AEs, and intercompany transactions catalogued.
Policy & Benchmarking
TP policy aligned with benchmarking study results.
Documentation
Local File, Master File, and CbCR prepared.
Certification
Form 3CEB filed with the income tax department.
Defence
TP officer, DRP, and tribunal representation as required.
Why It Matters
Frequently Asked Questions
Services covering TP planning, documentation, benchmarking, filings, and dispute resolution.
Any entity with international transactions or specified domestic transactions with associated enterprises.
Yes, mandatory for every taxpayer with international or specified domestic transactions with AEs.
Comparison of related-party transactions with comparable third-party transactions to test arm's length.
An Advance Pricing Agreement between taxpayer and CBDT fixing TP methodology in advance.
Need End-to-End TP Support?
From policy design to ITAT defence — get the full transfer pricing lifecycle handled by a specialist Chartered Accountant team.
Engage TP Specialists or call +91 9819 000 511