Overview
Section 92D requires documentation
before the AO asks.
Transfer Pricing under Section 92 of the Income Tax Act mandates that every Indian company entering into international transactions with related parties exceeding Rs.1 crore in a financial year must maintain contemporaneous documentation justifying the arm's length price. Failure to maintain documentation attracts a penalty of 2% of the transaction value under Section 271AA.
Our AI-assisted documentation process produces a compliant Master File and Local File, benchmarks transactions against comparable uncontrolled transactions using public databases, and prepares Form 3CEB-ready annexures for your tax auditor.
Why This Matters
Transfer Pricing assessments have intensified. AOs are routinely adding back undocumented international related-party transactions and levying both primary TP adjustments and the 2% documentation penalty simultaneously. With AI-driven benchmarking, we produce documentation faster and at a fraction of the cost of traditional TP consultants.
What We Audit
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Related Party Identification
All international related parties identified per Section 92A. Ownership, control, and relationship maps prepared.
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Transaction Benchmarking
Arm's length price determined using Comparable Uncontrolled Price or TNMM method using public databases.
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Master File Preparation
Group-level information, global value chain, and IP ownership structure documented per Rule 10DA.
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Local File Preparation
Entity-level documentation of each international transaction with functional analysis and benchmarking study.
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Form 3CEB Annexures
All annexures required for your Chartered Accountant's Form 3CEB certification prepared and ready.
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Advance Pricing Agreement Assessment
APA eligibility assessed for recurring high-value transactions where certainty is preferred.
What You Receive
Master File - Group-level TP documentation covering organisational structure, business overview, and IP policy.
Local File - Entity-level documentation with functional analysis, transaction details, and benchmarking study.
Benchmarking Report - Arm's length range established with comparable companies and transactions sourced from public databases.
Form 3CEB Annexures - All supporting schedules and annexures required for CA certification prepared and formatted.
Risk Register - High-risk transactions flagged with APA recommendation where appropriate.
30-Day Support - Queries from your tax auditor or AO on documentation addressed at no additional charge.