Transfer Pricing · Panaji, Goa
Complete transfer pricing compliance and advisory in Goa — documentation, benchmarking, Form 3CEB, audit defence, DRP representation, appeals, and APA guidance by qualified Chartered Accountants.
Overview
Transfer pricing is India's most complex area of corporate taxation. Sections 92 to 92F of the Income Tax Act require every international transaction between associated enterprises to be priced at arm's length. The Transfer Pricing Officer (TPO) has sweeping powers to adjust prices, and adjustments routinely run into crores — with penalties up to 200% of the resulting tax.
Whether you are an Indian subsidiary receiving management fees from a parent, a holding company lending to a subsidiary, or a domestic conglomerate with specified domestic transactions above ₹20 crore, our transfer pricing team brings the right mix of economic analysis, documentation rigour, and litigation experience. See our TP documentation and benchmarking analysis services for a deeper look.
Our services
From annual compliance to dispute resolution — one specialist practice for every TP requirement.
Talk to our CA →Contemporaneous documentation — Master File (Form 3CEAA), Local File, and the accountant's report (Form 3CEB) — filed by 31 October every year.
Selecting comparables from CAPITALINE, Prowess, or global databases; applying TNMM, CUP, or other methods; and computing the arm's length range for each transaction type.
Responding to notices from the Transfer Pricing Officer, presenting economic and factual arguments, and negotiating adjustments before the draft order is passed.
Filing objections to draft assessment orders within 30 days, presenting written and oral arguments to the DRP collegium, and achieving reduced or nil adjustments.
Drafting grounds of appeal, compiling case law, and presenting before CIT(A) and the Income Tax Appellate Tribunal for sustained TP adjustments.
Evaluating eligibility for unilateral or bilateral APAs, preparing the APA application, and advising on safe harbour elections under Rule 10TD for eligible IT/ITES and other service categories.
Key obligations at a glance
Accountant's report on international transactions and SDTs — filed electronically by 31 October of the assessment year.
Form 3CEAA (Master File) required for constituents of international groups with consolidated revenue above ₹500 crore or Indian transactions above ₹50 crore.
Form 3CEAD (CbCR) required for Indian holding companies of international groups with consolidated revenue above ₹5,500 crore (approximately USD 750 million).
Taxpayer has 30 days from the draft assessment order to file objections before the Dispute Resolution Panel.
Frequently asked questions
Transfer pricing governs prices for transactions between related parties across jurisdictions. India's rules under Sections 92–92F require all international transactions between associated enterprises to be at arm's length price (ALP). Non-compliance results in TP adjustments, penalties up to 200% of tax on under-reported income, and prolonged litigation before TPO, DRP, and appellate forums.
Any taxpayer with an international transaction with an associated enterprise, or a specified domestic transaction exceeding ₹20 crore, must comply. This includes Indian subsidiaries of foreign MNCs, Indian holding companies with overseas subsidiaries, JVs with foreign participation, and domestic groups with qualifying related-party transactions. Compliance requires annual Form 3CEB certification and contemporaneous documentation.
Form 3CEB is the accountant's report under Section 92E disclosing international and specified domestic transactions, the ALP method used, and the computed arm's length price. It must be certified by a CA and filed electronically by 31 October of the assessment year. Failure to file attracts a penalty of ₹1 lakh under Section 271BA.
The arm's length principle requires transactions between AEs to be priced as if between independent parties. India recognises six methods: CUP (Comparable Uncontrolled Price), RPM (Resale Price Method), CPM (Cost Plus Method), PSM (Profit Split Method), TNMM (Transactional Net Margin Method), and Other Method. TNMM is most commonly used in India due to its flexibility and availability of comparable data.
An APA is an agreement between the taxpayer and CBDT fixing the TP methodology and ALP for future transactions for up to 5 years, with a 4-year rollback option. APAs eliminate audit uncertainty and provide business certainty. They are recommended for taxpayers with large, recurring intercompany transactions who face repeated TP scrutiny. India has resolved over 600 APAs since the programme began.
The DRP is a three-member panel of senior tax officers under Section 144C. When a TPO makes an adjustment and the AO issues a draft order, the taxpayer has 30 days to file objections before the DRP. The DRP can enhance, reduce, or confirm the draft order. DRP proceedings are often faster than CIT(A) for eligible taxpayers and allow oral and written submissions.
We provide end-to-end TP services: transaction analysis, AE mapping, ALP method selection, contemporaneous documentation, benchmarking, Form 3CEB certification, TPO representation, DRP objections, CIT(A)/ITAT appeals, and APA/safe harbour advisory. Our qualified CAs in Panaji handle Indian subsidiaries of MNCs and domestic groups alike.
Explore our services
Book a free consultation with a qualified Chartered Accountant in Goa. We'll review your intercompany transactions, assess your exposure, and build a documentation and litigation strategy that stands up to scrutiny.