Last updated: 14 Oct 2026

Virtual Auditor

Transfer Pricing Disputes

Last updated: 14 Oct 2026

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What are transfer pricing disputes? Transfer pricing provisions (Sections 92-92F of the IT Act) require that international transactions between associated enterprises be priced at arm's length. When the Transfer Pricing Officer (TPO) determines that the arm's length price (ALP) differs from the transaction price, the resulting adjustment is added to the taxpayer's income. These adjustments can run into crores and require specialised defence. Virtual Auditor handles TP documentation review, TPO assessment response, DRP representation, and ITAT appeals. Quick Answer: Transfer Pricing Disputes — Transfer pricing dispute resolution. TPO adjustment challenges, DRP representation, ITAT appeals. Arm's length price documentation and defence for multinational companies.

Regulatory Framework

Transfer pricing in India is governed by Chapter X (Sections 92-92F) of the Income Tax Act, 1961 read with Rules 10A to 10E of the Income Tax Rules, 1962. Applicable to every international transaction with an Associated Enterprise (AE), with no monetary threshold, and to Specified Domestic Transactions (SDTs) exceeding Rs 20 crore (section 92BA). Documentation requirements: the Rule 10D documentation is mandatory once the aggregate value of international transactions in the year exceeds Rs 1 crore (Rule 10D(2)); the accountant's report in Form 3CEB under section 92E is required for every international transaction regardless of value. Country-by-Country Report (CbCR) under Section 286 for groups with consolidated revenue exceeding Rs 5,500 crore.

Scope of Services

TP Documentation Review TPO Assessment Defence DRP Representation ITAT Appeals on TP Adjustments Comparable Selection Challenge ALP Method Selection Defence Safe Harbor Rule Advisory APA (Advance Pricing Agreement) Support

Transfer Pricing — Dispute Resolution

ForumTime LimitBinding On
TPO determinationWithin 60 daysAO must adopt
DRP (Section 144C)9 months from draft orderAO must follow DRP direction
ITAT60 days from final orderBoth assessee and department
APA (Advance Pricing)12-24 monthsBinding for agreed period (5 years + 4 rollback)

Engagement terms — reviewed 25 October 2026

  • Fee: Transfer pricing study with Form 3CEB from ₹1,00,000 + 18% GST.
  • Extra / not included: Master file (Form 3CEAA) and CbCR filings, APA work and assessment representation are quoted separately.
  • Turnaround: 20 working days from receipt of complete information and the advance payment.
  • Who signs: The certificate is signed by V. Viswanathan FCA or another qualified Chartered Accountant of the practice, depending on the engagement.
  • Entity: Engagement letter and invoice are issued by V Viswanathan & Associates, Chartered Accountants (FRN 013713S), the proprietary firm of V. Viswanathan.
  • What to send first: Send list of related-party transactions with values, intercompany agreements, segmental profit and loss, and the group structure.
  • Next step: Send your enquiry on WhatsApp to +91 99622 60333; we confirm the scope, fee and timeline in writing before work starts.

Step-by-Step Process

    Step 1

    Identify international/domestic transactions

      Step 2

      Select most appropriate method (CUP/RPM/CPM/TNMM/PSM)

        Step 3

        Conduct benchmarking study with comparable data

          Step 4

          Prepare TP documentation and report

            Step 5

            File Form 3CEB with ITR

              Step 6

              Defend before TPO if selected for scrutiny

              Latest Regulatory Updates (FY 2025-26)

              This page has been updated to reflect changes introduced in Budget 2025, recent notifications from CBDT, CBIC, MCA, SEBI, and RBI, and evolving compliance requirements for FY 2025-26. Virtual Auditor continuously monitors regulatory developments to ensure all advice and filings are current and compliant with the latest provisions.

              Expert Guides & Research

              Deepen your understanding with our published research and practical guides:

              When Is Transfer Pricing Disputes Not Required?

              Transfer pricing documentation may not be required when: (a) the aggregate value of international transactions during the year does not exceed Rs 1 Cr, (b) there are no international transactions or specified domestic transactions, (c) the entity is not associated with any enterprise outside India, or (d) the transactions are covered under a safe harbour notification. However, TP certification in Form 3CEB is mandatory for all entities with international transactions or specified domestic transactions exceeding Rs 1 Cr.

              If you are unsure whether your situation requires transfer pricing disputes, contact us for a free preliminary assessment. We will advise you honestly — including telling you if you do not need our services.

              Documents Required

              The following documents are needed to take up a transfer pricing dispute:

              Group structure chart and the list of associated enterprises, inter-company agreements (services, royalty, loans, cost-sharing), segmental profit and loss for the international transactions, functions-assets-risks (FAR) inputs from the business teams, prior-year Form 3CEB and transfer-pricing study, master file and country-by-country report where the group thresholds apply, and any assessment or TPO notice already received.

              We provide a personalised document checklist after the initial consultation, tailored to your specific entity type and situation. Documents can be shared securely via email or our client portal.

              What You Receive

              Upon completion of the transfer pricing engagement, you will receive: the transfer-pricing study report under Rule 10D with the benchmarking workpapers and comparables search, Form 3CEB filed with the UDIN acknowledgment, a review note on the inter-company agreements and the pricing policy, master file (Form 3CEAA) and CbCR intimation (Form 3CEAC) only when separately commissioned, and a compliance calendar for the next year's transfer-pricing deadlines.

              All deliverables are reviewed by CA V. Viswanathan (FCA, ACS, CFE, IBBI RV) before release to ensure accuracy and regulatory compliance.

              What has changed in the law — reviewed October 2026

              • Income-tax Act, 2025: assented to on 21 August 2025 and in force from 1 April 2026, it replaces the Income-tax Act, 1961 for tax year 2026-27 onward, and the Income-tax Rules, 2026 (notified 20 March 2026) replace the 1962 Rules. Section and rule numbers on this page are those of the 1961 Act and 1962 Rules, which continue to govern assessments, appeals and pending proceedings for assessment years up to 2026-27; for tax year 2026-27 onward the corresponding provisions of the 2025 Act apply, and our engagement letters quote both.
              • CBDT Circular No. 07/2026 (28 September 2026): for AY 2026-27 the Section 44AB audit report was due 21 October 2026 and the return for audit cases (companies, audited businesses, partners of audited firms) is due 21 November 2026; transfer-pricing cases keep 31 October / 30 November; the circular does not waive Section 234A interest, and a return after 21 November is belated under Section 139(4) with no carry-forward of business loss. Read our note on the circular (virtualauditor.in/learn/cbdt-circular-07-2026-tax-audit-itr-extension-ay-2026-27/).

              Frequently Asked Questions

              What is a transfer pricing adjustment?
              When the TPO determines that the price charged in an international transaction is not at arm's length, the difference is added to the taxpayer's income as a transfer pricing adjustment. This increases taxable income and tax liability.
              What is DRP?
              Dispute Resolution Panel — a special mechanism under Section 144C for resolving transfer pricing and other international tax disputes. The taxpayer can choose DRP instead of CIT(A) for eligible cases. DRP must dispose of the matter within 9 months.
              Do you assist with Advance Pricing Agreements?
              Yes. APAs provide certainty by agreeing the arm's length methodology with the tax authority in advance (for up to 5 years, extendable by 4 years). We assist with unilateral, bilateral, and multilateral APA applications.
              When do transfer pricing rules apply?
              Every international transaction with an Associated Enterprise, with no monetary threshold — Form 3CEB under section 92E is required whatever the value, and the Rule 10D documentation once the aggregate exceeds ₹1 crore in the year. Specified Domestic Transactions exceeding ₹20 crore. Associated Enterprise: 26%+ shareholding, common management, or control dependency.
              What is the arm-length principle?
              Transactions between related parties must be priced as if they were between independent parties. Methods: CUP (Comparable Uncontrolled Price), RPM (Resale Price), CPM (Cost Plus), TNMM (Transactional Net Margin), PSM (Profit Split). Most appropriate method selected.
              What is the penalty for transfer pricing non-compliance?
              Section 271G: ₹1 lakh for failure to furnish documentation. Section 271BA: ₹1 lakh for failure to furnish audit report. Section 271AA: 2% of transaction value for failure to maintain prescribed documentation.
              Is transfer pricing study needed every year?
              Yes. Fresh TP documentation required every year even if transactions and pricing are same. Must be maintained before filing ITR. Benchmarking must use current year comparable data. We provide annual TP documentation retainers.
              What is APA and when should I consider it?
              Advance Pricing Agreement — binding agreement with CBDT on arm-length methodology. Unilateral (India only) or Bilateral (with treaty partner). For recurring large international transactions. Provides certainty for 5-9 years.
              Do these related-party dealings need transfer-pricing work, and what documentation will I receive?
              Transfer pricing applies to international transactions with associated enterprises, and to specified domestic transactions above ₹20 crore. Where the aggregate value of international transactions exceeds ₹1 crore, the prescribed documentation must be kept, and every entity with such transactions files an accountant’s report (Form 3CEB) by the due date (the Income-tax Act, 1961 for tax years up to 2025-26; the corresponding provisions of the Income-tax Act, 2025 from tax year 2026-27). Large groups also file a master file and country-by-country report. You receive a transfer-pricing study that maps each transaction, analyses functions, assets and risks, selects the method, benchmarks against comparable companies, and concludes on the arm’s length price, together with the certified report. If the price is adjusted in assessment, we support the objection and appeal.
              When is income tax return due in India?
              Non-audit cases: July 31. Audit cases (companies, firms requiring audit): October 31. Transfer pricing: November 30. Belated returns: December 31 with ₹5,000 late fee.
              What is TDS and who must deduct it?
              Tax Deducted at Source — every person making specified payments (salary, rent, professional fees, interest, contractor payments) must deduct TDS at prescribed rates and deposit with the government.

              Available Across India

              Transfer Pricing Services in every state and major city. Click to view location-specific details, fees, and regulatory information.

              States (28)
              Andhra PradeshArunachal PradeshAssamBiharChhattisgarhGoaGujaratHaryanaHimachal PradeshJharkhandKarnatakaKeralaMadhya PradeshMaharashtraManipurMeghalayaMizoramNagalandOdishaPunjabRajasthanSikkimTamil NaduTelanganaTripuraUttar PradeshUttarakhandWest Bengal
              Union Territories (8)
              Andaman & NicobarChandigarhDadra Nagar Haveli & Daman DiuDelhiJammu & KashmirLadakhLakshadweepPuducherry
              Cities (80)
              Adyar, ChennaiAgraAhmedabadAmbattur, ChennaiAmritsarAndheri, MumbaiAnna Salai, ChennaiAurangabadBannerghatta Road, BangaloreBhopalBhubaneswarBKC, MumbaiChandigarh CityCoimbatoreDehradunElectronic City, BangaloreFaridabadFort Churchgate, MumbaiGhaziabadGoa CityGoregaon, MumbaiGuindy, ChennaiGurugramGuwahatiHebbal, BangaloreHSR Layout, BangaloreHubli DharwadHyderabadIndiranagar, BangaloreIndoreJaipurJammuJayanagar, BangaloreJodhpurKanpurKochiKolkataKoramangala, BangaloreLower Parel, MumbaiLucknowLudhianaMaduraiMalad, MumbaiMangaloreMarathahalli, BangaloreMeerutMG Road, BangaloreMylapore, ChennaiMysuruNagpurNariman Point, MumbaiNashikNavi Mumbai, MumbaiNew DelhiNoidaNungambakkam, ChennaiOMR, ChennaiPanajiPatnaPorur, ChennaiPowai, MumbaiPuneRaipurRajkotRanchiSalemShimlaSuratT Nagar, ChennaiThane CityThane, MumbaiThiruvananthapuramTiruchirappalliUdaipurVadodaraVaranasiVelachery, ChennaiVijayawadaVisakhapatnamWhitefield, Bangalore

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