Transfer Pricing Study & Report (Form 3CEB)

Income Tax Act, 1961: Section 92 — computation of income from international transactions with Associated Enterprises (AEs) at arm's length price (ALP); Section 92A — AE definition (≥26% voting power or management/capital/control participation); Section 92B — international transaction definition; Section 92C — ALP computation methods (CUP, RPM, CPM, TNMM, PSM, or other method); Section 92CA — reference to Transfer Pricing Officer (TPO); Section 92D — maintenance of prescribed information and documents; Section 92E — mandatory accountant's report in Form 3CEB, due on or before the income-tax return due date; Section 92F — definitions.

Income Tax Rules, 1962: Rule 10A to 10E — transfer pricing methods and documentation; Rule 10D — mandatory contemporaneous documentation where aggregate international transaction value exceeds ₹1 crore.

Tolerance range: Section 92C(2) — arm's length range of 1% (wholesale trading) or 3% (other transactions) around the ALP; if the transacted price falls within this range, no adjustment is made.

Country-by-Country Reporting: Section 286 (inserted by Finance Act 2016) — CbCR obligations for constituent entities of an international group with consolidated group revenue above the prescribed threshold; Form 3CEAC (constituent entity notification), Form 3CEAD (CbCR itself), Form 3CEAA (Master File).

Advance Pricing Agreement: Sections 92CC/92CD — unilateral, bilateral or multilateral APAs with the CBDT, valid up to 5 years, with roll-back available for 4 preceding years.

Safe Harbour Rules: Rule 10TD — prescribed safe harbour margins for eligible international transactions (software development, ITeS, contract R&D, intra-group loans, corporate guarantees), opted into via Form 3CEFA.

We prepare transfer pricing study documentation, benchmark analysis coordination, related-party transaction review, and Form 3CEB reporting. This is required for Indian taxpayers with international transactions or specified domestic transactions under the Income-tax Act.