Last updated: 14 Oct 2026

Virtual Auditor

Section 92 Transfer Pricing Compliance

Last updated: 14 Oct 2026

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Quick answer: Transfer pricing compliance under Section 92D and Rule 10D requires documentation and benchmarking for international transactions. Services include preparing the Master File, Local File, and CbCR, conducting FAR analysis, determining the Arm's Length Price using prescribed methods, and providing representation during tax audit defence and appellate proceedings to minimize TPO adjustments.

Looking for expert section 92 transfer pricing compliance? 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 Section 92 Transfer Pricing Compliance?

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 section 92 transfer pricing compliance? 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.

Frequently Asked Questions

When is section 92 transfer pricing compliance 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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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.92 to s.92F, Income-tax Act 1961; Rules 10A to 10TG

Every international transaction and specified domestic transaction with an associated enterprise must be at arm's length, computed by one of the six methods under s.92C, documented under s.92D and Rule 10D, and reported by a chartered accountant in Form 3CEB. The Transfer Pricing Officer tests the benchmarking and can adjust income. 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. Identify associated enterprises and transactions
  2. Select the most appropriate method and tested party
  3. Benchmark with contemporaneous comparables
  4. Prepare the local file and master file where thresholds apply
  5. Obtain Form 3CEB and file before the return due date
Time limitForm 3CEB by 31 October (one month before the return due date of 30 November); documentation kept for 8 years
FormsForm 3CEB; Form 3CEAA (master file); Form 3CEAD (CbCR)
Consequence of defaultPenalty of 2% of the transaction value for failure to keep documents (s.271AA) and Rs 1 lakh for failure to furnish Form 3CEB (s.271BA)

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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