The Classic Partners LLP

Transfer Pricing Documentation

Section 92D and Rule 10D require contemporaneous documentation for related-party transactions — plus Master File and Country-by-Country reporting for larger groups. We build and maintain the complete three-tier file.

Build Your TP File

Tier 1 — Local File (Rule 10D)

Taxpayers with international transactions exceeding Rs. 1 crore in aggregate must maintain prescribed documentation: ownership and group profile, business and industry description, transaction details, FAR analysis, method selection, comparable data, and the workings of the arm's length price. Records must be kept for eight years and produced within the time allowed when the TPO calls for them.

Even below the threshold, documentation sufficient to substantiate the ALP is expected — the TP study is how this is delivered in practice.

Tier 2 & 3 — Master File and CbCR

Master File (Form 3CEAA): required where consolidated group revenue exceeds Rs. 500 crore and international transactions cross prescribed values — covering group structure, intangibles, financing, and global TP policies. Intimation in Form 3CEAB applies for multiple constituent entities.
Country-by-Country Report (Form 3CEAD): for international groups with consolidated revenue above Rs. 6,400 crore (aligned to EUR 750 million), reporting revenues, profits, taxes, and substance by jurisdiction; Form 3CEAC intimation identifies the filing entity.
Due dates align to the return cycle; defaults attract specific penalties including Rs. 5,00,000 for CbCR-related failures.

Penalties for Documentation Failures

Section 271AA: 2% of transaction value for failure to keep/maintain documents or for furnishing incorrect information.
Section 271G: 2% of transaction value for failure to furnish documents demanded in assessment.
Section 271BA: Rs. 1,00,000 for failure to file Form 3CEB.
Strong documentation also blunts penalty for under-reporting when adjustments are made in good-faith positions.

Our Documentation Services

Rule 10D Local File

Complete contemporaneous file aligned with the study and 3CEB.

Master File & CbCR

Forms 3CEAA/3CEAB/3CEAC/3CEAD preparation and e-filing.

Annual Refresh

Updated benchmarking and facts each year.

Gap Remediation

Fixing prior-year files before the TPO finds the gaps.

Group Coordination

Aligning Indian files with global policies via international tax.

Assessment Production

Organised submission when the TPO calls for records.

Frequently Asked Questions

Who must maintain transfer pricing documentation in India?

Taxpayers whose aggregate international transactions exceed Rs. 1 crore must maintain the full Rule 10D documentation; below that, information sufficient to substantiate the arm's length price is still required.

What is the three-tier documentation structure?

The Local File under Rule 10D, the Master File in Form 3CEAA for groups above Rs. 500 crore consolidated revenue with prescribed transaction levels, and the Country-by-Country Report in Form 3CEAD for groups above Rs. 6,400 crore.

How long must TP documentation be preserved?

For eight years from the end of the relevant assessment year, and it must be contemporaneous — created by the return due date, not reconstructed during assessment.

What are the penalties for not maintaining documentation?

2% of the transaction value under Section 271AA for failure to maintain (or for incorrect reporting), a further 2% under Section 271G for failure to furnish on demand, and Rs. 1,00,000 under Section 271BA for not filing Form 3CEB.

Does documentation help even if an adjustment is made?

Yes. A genuine, contemporaneous file demonstrates good faith and due diligence, which protects against under-reporting penalties and substantially strengthens DRP and appellate outcomes.

Is your TP file actually defensible?

Get a Rule 10D, Master File, and CbCR package built to be produced — not just stored.