TP Laws
Understanding the transfer pricing legal framework that governs related-party and specified domestic transactions in India.
Transfer pricing in India is governed primarily by Sections 92 to 92F of the Income Tax Act, which require international transactions and specified domestic transactions between associated enterprises to be priced at arm's length. The law prescribes specific methods for determining arm's length price, mandatory documentation and reporting obligations, and a distinct assessment and dispute-resolution mechanism separate from regular scrutiny. Non-compliance carries its own penalty structure, making early legal clarity important.
What the TP legal framework covers
Before pricing or documentation questions arise, it helps to be clear on which transactions the law actually reaches and how.
- Determining whether parties qualify as associated enterprises
- Identifying international transactions and specified domestic transactions
- Understanding the arm's length price standard and permitted methods
- Reviewing safe harbour rules and Advance Pricing Agreement options
- Mapping applicable reporting thresholds and due dates
- Understanding the penalty framework for non-compliance
What this service includes
How we help you navigate the legal framework.
AE & Transaction Mapping
Establishing which entities and transactions fall within the transfer pricing regime.
Method Selection Guidance
Advising on the most appropriate arm's length pricing method for your fact pattern.
Safe Harbour & APA Review
Assessing eligibility for safe harbour rules or an Advance Pricing Agreement.
Compliance Calendar
Mapping out reporting and filing deadlines specific to your transaction profile.
Our process
From initial consultation to completion.
Entity & Transaction Review
Identifying associated enterprises and the transactions between them.
Applicability Assessment
Determining which provisions and thresholds apply to your situation.
Method & Strategy Selection
Advising on the pricing method and compliance route best suited to the facts.
Compliance Roadmap
Setting out the documentation, reporting and filing obligations ahead.
Why legal clarity matters before you price a transaction
What sets our approach apart.
Wrong AE determination undermines everything downstream
If the associated-enterprise analysis is off, documentation and pricing built on it won't hold up.
Safe harbour and APA routes can reduce dispute risk
Understanding these options early can materially change your compliance and litigation exposure.
Penalties apply even for documentation lapses
The law penalises inadequate documentation separately from pricing adjustments, so process matters as much as outcome.
TP law questions answered
What people ask before engaging us.
Need clarity on your transfer pricing obligations?
Let our team help you navigate this process with clarity and confidence.
