TP Assessment · Panaji, Goa
Expert guidance through the transfer pricing assessment process — from Section 92CA TPO referral and draft order to DRP or CIT(A) — by qualified Chartered Accountants in Goa.
Overview
A transfer pricing assessment begins when the Assessing Officer (AO) selects a case for TP scrutiny, refers the international transactions to the Transfer Pricing Officer (TPO) under Section 92CA, receives the TPO's ALP order, and then incorporates the resulting adjustment into the assessment order. The entire cycle — from notice to final order — can take 2 to 4 years, culminating in a potentially large demand with interest under Sections 234B and 234C.
Understanding the timeline, the interplay between the AO and TPO, and the precise windows for objections and responses is critical to managing TP assessment risk. We coordinate across the TPO audit, DRP proceedings, and appellate stages as an integrated strategy.
What we cover
From Section 92CA referral to the final order — a coordinated strategy across the entire assessment cycle.
Talk to our CA →When the AO refers international transactions to the TPO, we immediately activate the documentation package, prepare FAR summaries, and engage proactively with the TPO to shape the audit scope.
Responding to notices under Sections 143(2) and 142(1) with accurate and complete information, avoiding inadvertent admissions that could be used against the taxpayer in the TPO proceedings.
Managing the information flow between the AO's main assessment and the TPO's TP proceedings, ensuring consistency of positions and preventing contradictory statements in different forums.
Analysing the draft assessment order immediately on receipt to identify every TP and non-TP variation, quantify the tax impact, and determine the optimal response — DRP objection or acceptance with CIT(A) planning.
Computing the exact tax demand and interest under Sections 234B and 234C arising from the TP adjustment, and advising on whether to pay the demand or apply for a stay pending appeal.
After the final assessment order, advising on rectification of errors under Section 154, stay applications, and filing the appellate route — CIT(A) or ITAT — with correct grounds and timelines.
The assessment timeline
AO issues Section 143(2) notice initiating scrutiny assessment — must be issued within 6 months of filing the return.
AO refers TP transactions to TPO. TPO independently investigates ALP — may take 12-24 months.
AO issues draft order incorporating TPO adjustment. Triggers 30-day DRP window.
Final assessment order and tax demand. Appeals to CIT(A) or ITAT must be filed within 30-60 days.
Frequently asked questions
A case can be selected for TP scrutiny based on risk parameters identified by the CBDT: significant international transactions, losses in the Indian entity despite group profit, high royalty or management fee payments, business restructurings, or specific industry selection. The scrutiny notice under Section 143(2) must be issued within 6 months of the end of the financial year in which the return was filed.
The AO conducts the overall income tax assessment — verifying deductions, income, and compliance. For TP matters, the AO is required under Section 92CA to refer the international transactions to the TPO, who independently determines the ALP. The AO must follow the TPO's ALP determination and incorporate it in the assessment order. The AO can raise non-TP adjustments independently alongside the TP adjustment.
The time limit for completing a TP assessment is 4 years from the end of the relevant assessment year (or 6 years if the aggregate value of international transactions exceeds ₹50 crore). Extensions apply if DRP directions are received or an audit is ordered. Appeals before ITAT and High Courts further extend the period within which the final demand can be recovered.
Interest under Section 234B (for shortfall in advance tax, at 1% per month) and Section 234C (for deferment of advance tax instalments, at 1% per month) is charged from the due date of advance tax to the date of assessment. In large TP adjustments, the interest component can exceed the principal tax demand — making early resolution through DRP or APA extremely valuable.
Yes. The AO can make non-TP adjustments (disallowances, additions to income) independently of the TPO's TP adjustment. Both are incorporated in the draft and final assessment orders. Taxpayers should therefore prepare for a holistic assessment defence — not just the TP component — when responding to scrutiny notices and providing information to the AO.
In some cases, the revenue makes a protective TP adjustment in an assessment where the same income has already been taxed in another entity or jurisdiction. This prevents the statute of limitations from expiring while the primary liability is determined. Taxpayers receiving protective assessments should coordinate with advisors in both jurisdictions to ensure the income is not taxed twice and seek DTAA Mutual Agreement Procedure (MAP) relief if necessary.
Related services
A coordinated strategy from the first AO notice through TPO, DRP, and appeal is the most effective way to manage TP assessment risk. Our qualified CAs in Panaji, Goa manage the entire cycle.