pvtltd.co

Direct Tax

Transfer Pricing

Transfer pricing documentation, benchmarking, BEPS compliance, and representation in TP disputes for cross-border related-party transactions. TP documentation, benchmarking studies, BEPS advisory, APA support, TPO/DRP representation.

Reviewed by CA Harun Raaj, ICAI Reg. No. 238303·Last reviewed:
Starting from Discuss with usTypical timelineTransfer Pricing

Transfer pricing documentation, benchmarking, BEPS compliance, and representation in TP disputes for cross-border related-party transactions. TP documentation, benchmarking studies, BEPS advisory, APA support, TPO/DRP representation. We keep the work founder-friendly and evidence-led so the company can move without unnecessary back-and-forth.

What is included
  • • Transfer Pricing scope review and action plan
  • • Document checklist and evidence review
  • • Drafting, computation, or filing support
  • • Submission support and acknowledgement tracking
  • • Follow-up on queries, corrections, or notices
  • • Closure notes and next-step reminders
Documents required
  • • PAN, Aadhaar, or entity tax data
  • • Form 16, AIS, 26AS, or return history
  • • Bank statements and ledgers
  • • Notice, contract, or transaction records, if any
Government fees

See the fee table below for the statutory filing charge and common delay logic.

Legal basis
  • • Section 92 of the Income-tax Act 1961
  • • Section 92C of the Income-tax Act 1961
  • • Section 92D of the Income-tax Act 1961
  • • Rule 10D of the Income-tax Rules 1962
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Process

How the service works

The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.

Step 1Scope

Confirm the scope

We map the exact service route to the trigger, form set, and documentary evidence so the work starts on the right footing.

Step 2Docs

Collect the records

We gather the company records, notices, or transaction documents needed for transfer pricing and check them for gaps.

Step 3Draft

Prepare the filing or memo

We draft the computations, filings, or advisory memo so the next person in the chain can review it quickly and confidently.

Step 4Close

Submit and track follow-up

We move the file through submission, keep the acknowledgement trail tidy, and handle any follow-up questions that come back.

AEO summary

Transfer Pricing is the CA-led workflow that helps a Private Limited company stay compliant, file the right forms, and keep the record trail clean.

Transfer Pricing workflow

We start by checking the exact trigger, the legal route, and the documents that make transfer pricing executable for a Private Limited company. That keeps the filing or advisory work tied to the actual statutory path instead of a generic checklist.

Once the scope is locked, we prepare the working papers, filings, and follow-up notes so the matter can move without unnecessary back-and-forth. The goal is to make the process understandable for the founder, the finance team, and the reviewer.

  • • Scope mapping for transfer pricing
  • • CA-led document review and drafting
  • • Submission support and acknowledgement tracking

What this protects for the company

For a Private Limited company, the value is not just speed. It is also about keeping the record trail clean enough for banks, investors, regulators, and future diligence work.

A founder-friendly process lowers the chance of avoidable notices, rework, or missed deadlines while keeping the company aligned with the right section, rule, or circular in Direct Tax.

  • • Cleaner compliance evidence for Direct Tax
  • • Better preparation for diligence or audit
  • • Less last-minute chasing inside the finance team

Government fees

Fee breakdown

ItemFeeNotes
E-filing or notice responseNilThe filing itself is usually fee-free, but late filing can attract fee or interest.
Statutory fee or taxAs applicableAny tax, interest, or appeal fee depends on the exact route.

Timeline

Typical turnaround

Typical timeline usually means a 1–2 weeks turnaround, assuming documents are complete and any board or shareholder approvals are already in place.

Pricing note

Fees can vary by filing type, entity class, and whether the work includes a reply, appeal, or connected computation.

Related services

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Support for Form 15CA/15CB.

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Support for FEMA FDI.

Tax Audit 44AB

Support for Tax Audit 44AB.

FAQ

Frequently asked questions

Which Private Limited companies are required to file Form 3CEB?
Section 92E requires a Form 3CEB report for any company entering into an international transaction or a specified domestic transaction. The brief uses a ₹1 crore practical trigger for detailed documentation, but the filing hook under Section 92E is the existence of the covered transaction.
What is the arm’s length standard under Section 92C?
Section 92C says the transaction price must be at arm’s length, meaning it should reflect what independent parties would have agreed to in comparable circumstances. The six recognised methods include CUP, RPM, CPM, PSM, TNMM, and the other-method residual route.
What documentation must be kept under Rule 10D?
Rule 10D requires entity details, transaction details, functional analysis, comparable selection, pricing computations, contracts, and support for the chosen method. The file should be built before the Section 92E due date, not after a notice arrives.
What is the penalty under Section 271AA?
Section 271AA can levy a penalty equal to 2% of the value of each international or specified domestic transaction where the required TP documentation is not maintained or furnished. That penalty is separate from any TP adjustment made in assessment.
Does transfer pricing apply to domestic transactions between related Indian companies?
Section 92 primarily targets international transactions, and only specified domestic transactions under Section 92BA also come in scope. Ordinary related-party transactions between two Indian companies are not automatically subject to transfer pricing unless they fall into those specified categories.

Canonical reference: https://www.pvtltd.co/services/transfer-pricing

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We can help with the filing, the legal mapping, and the follow-up work that keeps the company compliant after submission.

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