Last updated: 14 Oct 2026

Virtual Auditor

Master File Local File Transfer Pricing

Last updated: 14 Oct 2026

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Quick answer: Virtual Auditor provides expert transfer pricing services in India, including Master File, Local File, and CbCR documentation under Section 92D and Rule 10D. Led by CA V. Viswanathan, the service handles benchmarking, FAR analysis, and audit defence. Engagements are available in Chennai, Bangalore, and Mumbai with fixed-fee pricing provided upon consultation.

Looking for expert master file local file transfer pricing? Virtual Auditor provides practitioner-grade transfer pricing services in India, led by CA V. Viswanathan — Fellow Chartered Accountant (FCA) | Associate Company Secretary (ACS). We combine deep regulatory expertise with hands-on execution to deliver results within your timeline.

What is Master File Local File Transfer Pricing?

What We Deliver

Transfer pricing study report with benchmarking analysis and ALP determination. Transfer pricing documentation (Master File, Local File, CbCR) as per Rule 10D/10DA/10DB. Functional, Asset, and Risk (FAR) analysis for all international transactions. Benchmarking study using appropriate method (CUP, TNMM, RPM, CPM, PSM). TP audit defence submissions and hearing representation.

Our Process

Step 1: Transaction mapping and FAR analysis. Step 2: Selection of Most Appropriate Method (MAM). Step 3: Benchmarking analysis and ALP determination. Step 4: Report preparation compliant with Rule 10D/10DA. Step 5: Filing support and TP audit defence.

Our transfer pricing documentation includes economic analysis that anticipates common TPO adjustments — working capital adjustments, risk adjustments, comparability filters, and multiple year data analysis. This proactive approach means fewer audit adjustments and stronger defence positions.

Get Started Today

Ready to engage Virtual Auditor for master file local file transfer pricing? Contact us for a free initial consultation:

Call/WhatsApp: +91-99622 60333

Email: support@virtualauditor.in

Offices: Chennai | Bangalore | Mumbai

No obligation. We will assess your requirements and provide a clear scope, timeline, and fixed-fee quote within 24 hours.

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.

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.

Frequently Asked Questions

When is master file local file transfer pricing required?
Transfer pricing documentation is mandatory for entities with international transactions exceeding Rs 1 crore or specified domestic transactions exceeding Rs 20 crores in aggregate. The documentation must be maintained by the due date of filing the return of income.
What is the penalty for not maintaining transfer pricing documentation?
Failure to maintain TP documentation attracts penalty of 2% of the value of international transactions under Section 271AA. Additional penalties apply for non-filing of CbCR (Rs 5,000/day) and failure to furnish information (Rs 50,000/day).
How long does it take to prepare a transfer pricing study?
Typically 2-4 weeks depending on the number and complexity of international transactions. We recommend starting well before the return filing due date. Contact us at +91-99622 60333 for timeline confirmation.
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.

Related Services

Transfer Pricing DisputesTransfer Pricing Documentation CATransfer Pricing in AssamTransfer Pricing in AurangabadTransfer Pricing in BiharTransfer Pricing in ChhattisgarhTransfer Pricing in GoaTransfer Pricing in Gujarat

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Ready to Get Started?

Free 30-minute consultation with CA V. Viswanathan, FCA, ACS, CFE, IBBI RV. No obligation.

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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.

What the law says — s.92D(4), Income-tax Act 1961; Rule 10DA

A constituent entity of an international group must file the master file in Form 3CEAA (Part A always; Part B where consolidated group revenue exceeds Rs 500 crore and the entity's international transactions exceed Rs 50 crore, or intangible transactions Rs 10 crore). The local file under Rule 10D supports the arm's-length analysis of the entity's own transactions. The Income-tax Act, 2025 is in force from 1 April 2026 and applies to tax year 2026-27 onward; the section numbers above are those of the 1961 Act, which continues to govern assessments, appeals and pending proceedings for earlier years.

How does the procedure work?

  1. Test the Rule 10DA thresholds
  2. Collect group organisation, business and intangibles information from the parent
  3. Prepare Form 3CEAA Part A and, where required, Part B
  4. Prepare the local file under Rule 10D
  5. File by the return due date and retain for 8 years
Time limitForm 3CEAA by the return due date (30 November)
FormsForm 3CEAA; Form 3CEAB (designation of filing entity)
Consequence of defaultRs 5 lakh under s.271AA(2) for failure to furnish the master file

Source: Income-tax Act, 1961. Last reviewed 2026-10-14.

Which laws govern this service? — Transfer pricing

The statutory provisions this service is delivered under, linked to the official text:

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