Transfer Pricing in India: Navigating Compliance with Confidence

“The price of doing business globally shouldn’t be paid in double taxes or legal risks.”
— LegalTax Coin

Transfer pricing is not just a tax issue—it's a critical business decision that impacts profitability, compliance, and cross-border reputation. Whether you're a multinational, an Indian company with overseas dealings, or a growing business entering international markets, understanding and aligning with India’s transfer pricing laws is vital.

What Is Transfer Pricing?

Transfer pricing refers to the pricing of goods, services, or intellectual property exchanged between associated enterprises—such as a parent company and its subsidiary—operating under common control.

These transactions often differ from those between unrelated parties, which can lead to profit shifting and tax loss in jurisdictions like India. To address this, Indian tax laws mandate that all international or specified domestic transactions must be at an “Arm’s Length Price” (ALP)—a price that would be charged between unrelated parties in a similar transaction.

Legal Framework in India

Transfer Pricing Regulations were introduced in 2001, and key sections 92A to 92F and rules 10A to 10E of the Income Tax Act, 1961 govern the pricing of international and certain domestic transactions.

Taxpayers are expected to:

• • Use Arm’s Length Pricing
  • Maintain Transfer Pricing Documentation
  • Submit Form 3CEBcertified by a Chartered Accountant
  • Cooperate with the Transfer Pricing Officer (TPO), if approached

Transfer Pricing Methods Allowed by Indian Law

India recognizes 5 core methods and allows a 6th (any other prescribed method) in special circumstances. These are:

1. 1. Comparable Uncontrolled Price (CUP) Method
      Compares price of related-party transaction with similar transaction between unrelated parties.
   2. Resale Price Method
      Resale price to an independent party minus a standard margin.
   3. Cost-Plus Method
      Supplier’s cost plus a fair profit margin.
   4. Transactional Net Margin Method (TNMM)
      Net margin comparison—widely used due to flexibility.
   5. Profit Split Method
      Splits combined profits based on functions, risks, and assets contributed.
   6. Other Prescribed Methods
      As defined by CBDT in special cases.

Why Choose LegalTax Coin for Transfer Pricing Services?

We are among Delhi’s leading Transfer Pricing consultants, trusted by CFOs, tax heads, and multinational groups for:

🔹 TP Planning & Strategy – Optimise intercompany pricing models
🔹 Transfer Pricing Study & Documentation – End-to-end preparation
🔹 Form 3CEB Filing & Audit Support
🔹 Country-by-Country Reporting (CbCR)
🔹 Representation Before TPO & ITAT
🔹 Litigation Assistance – CIT(A), DRP, ITAT levels

“We don’t just ensure compliance—we ensure confidence.”

With years of experience in Statutory Audit, international tax structuring, and global transaction advisory, we deliver practical, legally sound, and industry-specific solutions.

Let's Talk Transfer Pricing

Whether you're a multinational enterprise or a growing startup, your cross-border transactions deserve attention and accuracy.

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“Where others see complexity, we deliver clarity. Let us help you price your success—right.”