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Transfer Pricing

Transfer Pricing Checker

Virtual AuditorPublished: 23 Mar 2026🕒 1 min readLast updated: 14 Aug 2026

Quick Answer

The Transfer Pricing Checker, authored by CA V. Viswanathan, assists in determining if transactions with Associated Enterprises (AEs) fall under Section 92 of the Income Tax Act, 1961. Available since 2012, this tool specifically evaluates whether international transactions with AEs trigger the application of mandatory transfer pricing provisions.

by CA V. Viswanathan
FCA, ACS, CFE, Registered Valuer (S&FA) | Since 2012

Check Transfer Pricing Applicability

Determine whether your transactions with Associated Enterprises (AEs) attract Transfer Pricing provisions under Section 92 of the Income Tax Act, 1961.

Frequently Asked Questions (FAQs)

1. What is the purpose of the Transfer Pricing Checker?

The Transfer Pricing Checker is designed to help users determine if their specific financial transactions conducted with Associated Enterprises (AEs) are subject to the transfer pricing provisions mandated under Section 92 of the Income Tax Act, 1961, as explained by the author CA V. Viswanathan.

2. When was the Transfer Pricing Checker made available?

The Transfer Pricing Checker resource has been available since 2012, as indicated by the professional profile details provided by the author, CA V. Viswanathan, who is a Fellow Chartered Accountant and Registered Valuer, in the context of checking transfer pricing applicability for businesses.

3. Which legal section governs transfer pricing applicability?

Transfer pricing applicability is determined based on the provisions set forth under Section 92 of the Income Tax Act, 1961. The Transfer Pricing Checker tool specifically directs users to evaluate their international transactions against these regulatory requirements to ensure compliance with the established tax laws.

4. How do I check if my transactions attract transfer pricing provisions?

To check if your transactions attract transfer pricing provisions, you must use the Transfer Pricing Checker to evaluate your international transactions with Associated Enterprises. The tool asks the user to confirm whether they have engaged in such international transactions to verify if the Section 92 provisions apply.

5. Is the Transfer Pricing Checker for international transactions?

Yes, the Transfer Pricing Checker is specifically focused on identifying whether international transactions conducted with Associated Enterprises (AEs) attract transfer pricing provisions under Section 92 of the Income Tax Act, 1961. The tool guides users through a simple inquiry regarding the nature of their dealings.

Transfer Pricing — Applicability and Compliance Framework

Transfer pricing under Sections 92-92F of the Income Tax Act applies to: (a) International transactions between associated enterprises (AEs) — no monetary threshold for applicability of arm's length pricing requirement, but Form 3CEB and TP study required where aggregate exceeds ₹1 crore; (b) Specified Domestic Transactions under Section 92BA where aggregate exceeds ₹20 crore.

Key compliances: Form 3CEB (CA-certified report) by 31 October; contemporaneous transfer pricing study supporting arm's length conclusion; CbCR (Country-by-Country Reporting) and Master File for groups with consolidated revenue exceeding ₹6,400 crore.

Methods under Rule 10B: Comparable Uncontrolled Price (CUP); Resale Price Method (RPM); Cost Plus Method (CPM); Profit Split Method (PSM); Transactional Net Margin Method (TNMM); and Any Other Method. Selection depends on transaction nature and data availability.

This checker helps determine TP applicability and likely method selection. For TP study preparation, audit defence at TPO/DRP/ITAT, or APA filing, consult CA V. Viswanathan at +91 99622 60333.

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