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Home / Tax & Compliance / Transfer Pricing
Last updated: 2 October 2026
If your business deals with overseas group companies or has large specified domestic transactions, Indian transfer pricing rules apply. Expertvuw’s team prepares the documentation and coordinates the accountant’s report, which is certified by an independent Chartered Accountant.
Transfer pricing rules require that transactions between associated enterprises — such as an Indian subsidiary and its foreign parent — are priced at arm’s length, as if the parties were independent. They cover sale and purchase of goods, services, royalties, loans, guarantees, cost allocations and share transactions.
Businesses with international transactions or specified domestic transactions must maintain prescribed documentation, obtain an accountant’s report, and in larger groups file a master file and country-by-country report. Transfer pricing officers can make adjustments where prices are not supported by a benchmarking analysis.
The Income-tax Act, 2025 continues the transfer pricing framework from 1 April 2026 with renumbered sections and forms. Filings and assessments for earlier years continue under the 1961 Act.
Basis: Income-tax Act, 1961 (Chapter X, sections 92 to 92F) and Income-tax Act, 2025; Income-tax Rules 10A to 10E; OECD Transfer Pricing Guidelines for reference. Last updated: 27 September 2026.
An accountant's report (Form 3CEB under the 1961 Act) is required for international and specified domestic transactions and must be certified by a Chartered Accountant.
Detailed documentation is required where international transactions exceed ₹1 crore in a year, as per the Rules.
Specified domestic transactions are covered where their aggregate exceeds ₹20 crore.
Constituent entities of groups above prescribed revenue and transaction thresholds must file a master file.
Safe harbour rules and Advance Pricing Agreements can provide certainty on pricing for eligible transactions.
Failure to maintain documentation or furnish the report can attract separate penalties, in addition to adjustments.
Most disputes come from weak documentation rather than wrong pricing.
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Transfer pricing often connects with these services.
Company returns that include transfer pricing disclosures.
Appeals against transfer pricing adjustments.
Valuations for share transactions between group entities.
RBI reporting for foreign investment and overseas entities.
Map associated enterprises and all covered transactions.
Understand functions, assets and risks of each party.
Select the method and search for comparables.
Prepare the TP study and supporting files.
Coordinate the accountant's report with an independent CA.
Assist with TPO queries and records during assessments.
Transfer pricing is annual, and some forms have separate due dates.
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Any taxpayer that has international transactions with associated enterprises, or specified domestic transactions above the threshold, must comply.
The accountant’s report must be certified by a Chartered Accountant. Expertvuw coordinates this with independent CAs.
It is the price that would apply if the transaction were between unrelated parties in similar conditions, determined using the methods prescribed in the Act and Rules.
The tax officer may make adjustments, and separate penalties can apply for not maintaining or furnishing documentation.
The framework continues with renumbered sections and forms from 1 April 2026. Earlier years remain under the 1961 Act.
ACS – Director, Expertvuw Management Pvt Ltd
Tax work is handled by Expertvuw’s team. Audits and certifications required by law are issued by independent Chartered Accountants, and representation before tax authorities and tribunals is made by authorised professionals or advocates.