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.