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We are proud to offer credible Transfer Pricing Services in Gurgaon, which offer effqective solutions to companies that undertake international transactions or specified domestic transactions with its associated enterprise(s) / group companies. We also provide credible consultancy, documentation, compliances, and allied Transfer Pricing Services.
Transfer pricing refers to the setting of the price for goods & services that are sold within an enterprise that too between controlled legal entities. For instance, if the goods are sold to a parent company by a subsidiary company, the cost of that the parent company pays to the subsidiary is termed as the ‘transfer price’.
The Transfer Pricing Laws as mentioned u/s 92 to 92F of the Income Tax Act 1961 covers cross-border intra-group transactions. For tax purposes, companies need to follow the arms-length principle to record the exchange of goods, which implies that the prices that the affiliated companies charges should be equivalent to the prices charged by a third-party. The prescribed methods under this Act are given below:
Comparable uncontrolled price methodProfit split methodResale price methodCost-plus methodTransactional net margin methodHowever, other methods can be used that take into account the price that has been charged for the same transaction under similar circumstances, with or between non-associated enterprises, taking into consideration all the relevant facts.
It can be further divided into two parts-
If you want to know more about Transfer Pricing Services in Gurgaon. contact us.
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Looking for expert Chartered Accountants for Transfer Pricing in Gurgaon? AVC India delivers comprehensive TP documentation, benchmarking analysis, Accountant’s Report in Form 3CEB, Master File and CbCR compliance, and strategic defense for Transfer Pricing Assessments and Appeals across Delhi NCR.
Under India’s Transfer Pricing regulations governed by Sections 92 to 92F of the Income Tax Act, 1961, and the OECD BEPS framework, every international transaction or specified domestic transaction between associated enterprises must be conducted at Arm’s Length Price (ALP). With the Income Tax Department’s expanding use of risk-based audits, automated data analytics, and country-by-country reporting algorithms, multinational enterprises operating in Gurgaon face unprecedented scrutiny of their cross-border and related-party transactions.
At AVC India (Aggarwal Varun & Co.), we provide comprehensive Transfer Pricing study, documentation, and assessment defense services in Gurgaon for multinational corporations, IT/ITeS exporters, captive service providers, auto component manufacturers, and trading conglomerates across DLF Cyber City, Udyog Vihar, Golf Course Road, and IMT Manesar.
Our seasoned Chartered Accountants conduct meticulous functional, asset, and risk (FAR) analysis, perform robust benchmarking studies using global databases, prepare entity-level TP documentation, and certify Form 3CEB to ensure your related-party transactions withstand departmental scrutiny.
When tax authorities initiate Transfer Pricing Assessments under Section 92CA or propose adjustments, our senior partners lead the technical defense compilation, represent your business before the Transfer Pricing Officer and Dispute Resolution Panel, and resolve proposed adjustments before draft assessment orders are issued.
A systematic TP study establishes defensible arm’s length pricing, minimizes adjustment risk, and shields your business from heavy penalties and double taxation.
Proactive TP documentation and benchmarking identify and resolve pricing gaps before tax authorities issue notices under Section 92CA or propose adjustments to your international transactions.
Robust TP studies with contemporaneous documentation support Mutual Agreement Procedure (MAP) and APA applications, preventing taxation of the same income in two jurisdictions.
Complete reconciliation between financial statements, Form 3CEB disclosures, and TP documentation ensures 100% data consistency across tax audit and regulatory filings.
Identifying ALP discrepancies early allows voluntary adjustment and documentation, avoiding mandatory penalty exposure of 100% to 300% of tax on under-reported income.
Our senior chartered accountants provide structured TP documentation, benchmarking, and compliance services across diverse multinational and domestic entities in NCR.
MNCs with Indian subsidiaries, branches, or liaison offices engaged in imports, exports, management fees, royalty, or technical service payments must maintain TP documentation. We prepare comprehensive TP studies covering all international transactions with associated enterprises and certify Form 3CEB for annual compliance.
Manufacturing corporations dealing with raw material imports from group entities, contract manufacturing arrangements, and technology transfer agreements face complex TP audits involving TNMM, CUP, and profit split methods. Our TP study verifies full statutory adherence across your entire supply chain.
Software exporters and captive service providers in Gurgaon manage zero-rated supplies, cost-plus service arrangements, software development services, and secondment of employees. We audit your intercompany agreements and cost allocations to protect your profit margins and tax positions.
Businesses claiming deductions under Sections 80-IA, 80-IB, 80-IC, or 10AA, and those with related-party transactions exceeding ₹20 Crore, must comply with TP regulations for specified domestic transactions. We prepare SDT documentation and certify compliance under Section 92BA.
If your enterprise has received a notice from the Transfer Pricing Officer proposing an adjustment to your ALP, you have limited time to respond with benchmarking evidence. We manage the entire TP assessment process, organize documentation, and draft technical replies to show-cause notices.
Multinational enterprise groups with consolidated revenue exceeding €750 million must file Country-by-Country Report (Form 3CEAD) and Master File (Form 3CEAA). We prepare three-tier documentation (Master File, Local File, CbCR) ensuring full BEPS Action 13 compliance.
Keep these core financial, intercompany, and benchmarking files ready for our chartered accountancy TP team.
A systematic, CA-led TP framework ensuring 100% benchmarking accuracy, documentation integrity, and audit defense readiness.
We conduct detailed functional, asset, and risk (FAR) analysis of your Indian entity and associated enterprises to determine the appropriate TP method and tested party.
We identify and map all international and specified domestic transactions, including imports, exports, management fees, royalties, and loans, with intercompany agreement review.
We perform robust comparable company searches using Prowess, Capitaline, ORBIS, and global databases to determine the arm’s length price range and interquartile margins.
We select the most appropriate TP method (TNMM, CUP, RPM, PSM, or Cost Plus) and compute the arm’s length price for each transaction category.
Our senior CAs prepare comprehensive entity-level TP documentation, Local File, and Accountant’s Report in Form 3CEB certifying ALP compliance.
For qualifying MNE groups, we prepare and file Form 3CEAA (Master File), Form 3CEAC (CbCR notification), and Form 3CEAD (Country-by-Country Report).
We represent your business before the Transfer Pricing Officer, DRP, and ITAT, and assist with Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) applications.
We conduct detailed functional, asset, and risk (FAR) analysis of your Indian entity and associated enterprises to determine the appropriate TP method and tested party.
We identify and map all international and specified domestic transactions, including imports, exports, management fees, royalties, and loans, with intercompany agreement review.
We perform robust comparable company searches using Prowess, Capitaline, ORBIS, and global databases to determine the arm's length price range and interquartile margins.
We select the most appropriate TP method (TNMM, CUP, RPM, PSM, or Cost Plus) and compute the arm's length price for each transaction category.
Our senior CAs prepare comprehensive entity-level TP documentation, Local File, and Accountant's Report in Form 3CEB certifying ALP compliance.
For qualifying MNE groups, we prepare and file Form 3CEAA (Master File), Form 3CEAC (CbCR notification), and Form 3CEAD (Country-by-Country Report).
We represent your business before the Transfer Pricing Officer, DRP, and ITAT, and assist with Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) applications.
Every TP study, benchmarking analysis, and Form 3CEB certification is directly reviewed by CA Varun Aggarwal (FCA) and senior transfer pricing specialists.
We have successfully represented over 250+ clients during Section 92CA TP assessments, DRP proceedings, and appellate defense before ITAT and High Courts.
We leverage advanced analytical tools and global databases (Prowess, Capitaline, ORBIS, TP Catalyst) to identify the most defensible comparable companies for your industry.
We understand the specific operational dynamics of Gurgaon’s MNC IT headquarters, Manesar auto component manufacturers, and captive service providers.
We maintain strict TP compliance schedules to ensure your Form 3CEB and TP documentation are prepared and filed well before the statutory due date.
Your complete intercompany agreements, pricing policies, and financial ledgers are protected under non-disclosure agreements and encrypted storage systems.
Under the Income Tax Act, 1961, and the OECD Base Erosion and Profit Shifting (BEPS) framework, transfer pricing regulations ensure that international transactions and specified domestic transactions between associated enterprises are conducted at arm’s length. A transfer pricing study involves examining intercompany transactions, conducting functional analysis, benchmarking comparable companies, and determining the Arm’s Length Price (ALP) to ensure fair profit allocation across jurisdictions.
In a dynamic commercial hub like Gurugram featuring high-volume captive service providers in DLF Cyber City, multinational manufacturing units in IMT Manesar, and extensive trading networks navigating transfer pricing compliance demands rigorous data reconciliation across both direct and indirect tax dimensions.
The transfer pricing law provides for distinct compliance mechanisms depending on transaction value, entity type, and group structure:
| Compliance Category | Governing Section / Rule | Applicability / Trigger | Conducting Authority / Form |
|---|---|---|---|
| Form 3CEB Certification | Section 92E / Rule 10E | Mandatory for all entities with international or specified domestic transactions | Accountant's Report in Form 3CEB |
| TP Study & Documentation | Section 92D / Rule 10D | Mandatory for all entities with international transactions | Entity-level TP documentation and benchmarking |
| Master File | Section 92D(4) / Rule 10DA | MNE groups with consolidated revenue > €750 million | Filed in Form 3CEAA |
| Country-by-Country Report | Section 92D(4) / Rule 10DB | MNE groups with consolidated revenue > €750 million | Filed in Form 3CEAD |
| TP Assessment | Section 92CA | Selected based on risk parameters by TPO | Notice from Transfer Pricing Officer |
| Specified Domestic Transactions | Section 92BA | Related-party transactions exceeding ₹20 Crore | Form 3CEB and TP documentation |
While often prepared together before the statutory due date (October 31 following the financial year-end), Form 3CEB and TP Study serve distinct statutory purposes:
During a TP assessment or pre-audit health check, our Chartered Accountants scrutinize the following high-risk compliance parameters:
When the Transfer Pricing Officer selects an enterprise for a TP assessment, the statutory procedure follows a strict timeline:
Filing Form 3CEB is mandatory for all taxpayers who have entered into international transactions or specified domestic transactions with associated enterprises, regardless of turnover. There is no minimum threshold. However, TP documentation under Section 92D must be maintained by all entities with international transactions exceeding ₹1 Crore or specified domestic transactions exceeding ₹20 Crore.
Yes. Form 3CEB is an Accountant's Report that must be certified by a practicing Chartered Accountant. The CA certifies that the international transactions and specified domestic transactions are at arm's length and that proper TP documentation has been maintained by the taxpayer.
A Section 92CA notice requires you to submit TP documentation, benchmarking analysis, and intercompany agreements within the specified timeframe. Our senior CA team prepares your complete TP defense dossier, conducts a mock TP audit, and represents your company before the TPO to resolve queries and minimize adjustments.
Yes. If discrepancies are identified during a TP audit, you can voluntarily revise your TP documentation, adjust your transfer prices, and file a revised Form 3CEB before the assessment is finalized. Voluntary compliance before a formal adjustment order reduces penalty exposure significantly.
The statutory due date for filing Form 3CEB is October 31 following the close of the relevant financial year (unless extended by the CBDT). TP documentation under Section 92D must be maintained and updated contemporaneously and should be available for submission within 30 days of a request from the tax authorities.
Schedule a confidential consultation with CA Varun Aggarwal (FCA) and our senior transfer pricing advisory team in Sector 31, Gurugram. Establish defensible arm’s length pricing, secure your intercompany transactions, and ensure complete TP audit readiness.
