Form 3CEB
Benchmarking
Safe Harbour
Transfer Pricing Advisory Services in Pune
When enterprises transact with their associated enterprises — whether across international borders or within India — the pricing of these inter-company transactions must comply with the arm’s length principle prescribed under the Income Tax Act, 1961. Transfer pricing regulations are designed to prevent profit shifting and ensure that taxable income is accurately reported in each jurisdiction. CA D P Shewale & Co LLP assists multinational enterprises (MNEs) and domestic groups with comprehensive transfer pricing study, benchmarking, documentation, and compliance services.
Why Transfer Pricing Compliance Is Critical
Non-compliance with transfer pricing regulations can lead to severe consequences, including adjustment of income by the Assessing Officer, penalties up to 2% of the transaction value for documentation failures, and prolonged litigation. The Indian transfer pricing framework has evolved significantly, with the introduction of domestic transfer pricing provisions, Country-by-Country Reporting (CbCR) requirements, and safe harbour rules. Our team stays current with all regulatory developments and judicial precedents to provide you with robust, defensible transfer pricing positions.
Our Transfer Pricing Services
End-to-end transfer pricing support — from documentation and certification to dispute resolution before the TPO, DRP, and appellate authorities.
TP Study & Documentation
Comprehensive TP study reports covering functional analysis, economic analysis, selection of the Most Appropriate Method (MAM), benchmarking using Prowess/Capitaline databases, and Rule 10D documentation preparation.
Form 3CEB Certification
Chartered Accountant certification of the report on international and specified domestic transactions under Section 92E, ensuring all related-party transactions are accurately reported and documented.
Benchmarking Analysis
Selection of comparable companies, application of appropriate TP methods (CUP, TNMM, RPM, CPM, PSM), and computation of arm’s length price or margin with statistical adjustments and interquartile range analysis.
Safe Harbour Rules Advisory
Evaluation of eligibility under the Safe Harbour Rules notified by CBDT, which provide predetermined margins for certain categories of international transactions, simplifying compliance and reducing litigation risk.
Domestic Transfer Pricing
Advisory and documentation for specified domestic transactions (SDTs) under Section 92BA, applicable when transactions with related parties or entities claiming profit-linked deductions exceed Rs 20 crore.
TP Dispute Resolution
Representation before the Transfer Pricing Officer (TPO), Dispute Resolution Panel (DRP), and appellate authorities for transfer pricing adjustments and penalty proceedings.
Transfer Pricing Compliance — Key Facts
Understanding the documentation and penalty framework helps you appreciate what is at stake with transfer pricing compliance:
- Who Must Comply — Enterprises with international transactions or specified domestic transactions with associated enterprises
- Documentation Requirement — Prescribed under Section 92D and Rule 10D of the Income Tax Rules
- Form 3CEB Deadline — On or before 30th November (same as ITR due date for TP entities)
- Penalty — Documentation Failure — 2% of the value of each international transaction
- Penalty — Unreported Transaction — 2% of the value of the unreported transaction
- CbCR Applicability — Indian constituent entities of MNE groups with consolidated revenue above Rs 6,400 crore
Frequently Asked Questions
Who needs to maintain transfer pricing documentation?
What is the deadline for filing Form 3CEB?
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Related Services
Transfer pricing works in conjunction with your broader direct tax and corporate advisory strategy:
Defensible transfer pricing positions — every year.
Get your TP documentation reviewed by our specialists before the filing deadline.