Transfer Pricing Consultants in India
OECD-aligned TP documentation, benchmarking studies, APA advisory, and audit representation for MNCs and Indian companies with cross-border related-party transactions.
Led by CA Rupesh Khandelwal (ex-Deloitte) and CA Mehul Agrawal - combining Big 4 methodology with CA firm responsiveness.
Does Your Company Need Transfer Pricing Compliance?
India's TP compliance structure is tiered by transaction value. Most MNC subsidiaries and Indian companies with foreign group entities will trigger at least the basic Form 3CEB requirement.
Transfer Pricing Services
Master File & Local File
Preparation of the OECD-aligned Master File (Form 3CEAA) and Local File (Form 3CEAB) for Indian entities with international related-party transactions exceeding prescribed thresholds.
Form 3CEB - Accountant's Report
Mandatory CA certification of international transactions under Section 92E. We prepare and certify Form 3CEB covering all specified domestic and international transactions.
Benchmarking & Arm's Length Analysis
Selection of the most appropriate transfer pricing method (TNMM, CUP, RPM, CPM, PSM), database searches (Prowess, Capitaline, Bureau van Dijk), and preparation of a defensible benchmarking study.
Advance Pricing Agreement (APA)
Advisory and preparation support for unilateral, bilateral, and multilateral APA applications - including pre-filing meetings, rollback negotiations, and annual compliance reports.
TP Audit Representation
Representation before Transfer Pricing Officers (TPO) and Dispute Resolution Panel (DRP) in case of scrutiny assessment under Section 92CA. Drafting of responses to notices and appeal assistance up to ITAT.
Country-by-Country Reporting (CbCR)
CbCR preparation and filing for MNCs with consolidated group revenue exceeding ₹5,500 crore (approximately €750 million). Covers Form 3CEAD and master entity notification requirements.
Big 4 Methodology. CA Firm Accessibility.
Most mid-size companies can't afford Big 4 TP fees. We bring the same OECD-standard methodology - honed by our Deloitte-trained partner - at a fraction of the cost.
CA Rupesh Khandelwal
Partner - Ex-Deloitte
Rupesh brings deep Big 4 experience in domestic and international taxation. His background at Deloitte includes TP documentation, audit representation, and cross-industry advisory for pharma, IT, and auto clients.
CA Mehul Agrawal
Partner - International Tax
Mehul specialises in cross-border structuring, DTAA advisory, and FEMA compliance. He coordinates the TP work with broader international tax strategy - ensuring the transfer pricing policy aligns with India-UAE, India-US, and other treaty positions.
Transfer Pricing FAQs for India
Who needs to comply with transfer pricing in India?
Any Indian company that has related-party international transactions must comply with transfer pricing under Section 92 of the Income Tax Act. This includes: MNC subsidiaries in India transacting with their foreign parent or group entities, Indian companies with foreign subsidiaries, and joint ventures with foreign partners. Even a single transaction - a royalty payment, management fee, inter-company loan, or software service - above ₹1 crore triggers the Form 3CEB requirement.
What is the penalty for non-compliance with transfer pricing in India?
The penalties are severe: (1) Failure to maintain TP documentation - penalty of 2% of the value of international transactions; (2) Concealment of income through TP manipulation - penalty of 100–300% of the tax sought to be evaded; (3) Late or incorrect filing of Form 3CEB - ₹1 lakh per default. Beyond penalties, a TP audit can result in a significant upward adjustment to your taxable income, with interest running from the original assessment date.
What transfer pricing method is best for an Indian subsidiary providing IT services to a US parent?
For IT service subsidiaries (captives), the Transactional Net Margin Method (TNMM) using operating margin as the profit level indicator is the most commonly accepted method in India. A benchmarking study comparing the subsidiary's operating margin against comparable independent IT service companies (typically sourced from Prowess or Capitaline) determines the arm's length range. The IQR (interquartile range) of comparable companies defines the acceptable margin band.
Can a transfer pricing adjustment be avoided with an Advance Pricing Agreement?
Yes. An APA (Advance Pricing Agreement) with the CBDT provides certainty on the arm's length price for a specified period (typically 5 years), with the option to roll back up to 4 previous years. Once an APA is in place, the covered transactions cannot be subjected to TP audit for that period. APA is ideal for companies with recurring high-value related-party transactions and provides the strongest protection against arbitrary adjustments.
What is the difference between Form 3CEB, Master File, and Local File?
These are three distinct compliance requirements under India's transfer pricing regulations: Form 3CEB is a CA-certified report listing all international and specified domestic transactions - mandatory for any company with related-party transactions above ₹1 crore. The Local File (Form 3CEAB) provides detailed analysis of the Indian entity's transactions with its foreign related parties - triggered when international transactions exceed ₹100 crore. The Master File (Form 3CEAA) provides a high-level overview of the entire multinational group's business, structure, and TP policies - required when the group's consolidated revenue exceeds ₹1,000 crore.
Need Transfer Pricing Documentation?
Don't wait for a notice. TP documentation must be in place before the due date - and should be updated every year. Contact us to get started.