Sanjeev Dua & Associates — Chartered Accountants
Cross-Border Taxation

Transfer Pricing

Specialized transfer pricing advisory, documentation studies, Master File reporting, and independent certification for international and specified domestic transactions.

Scope of Practice

What We Cover

Approved statutory and professional services under this practice area.

Form 3CEB under section 92E
TP documentation
Master Files
TP advisory and assessments
Practice Overview

Service Overview

In an increasingly interconnected global economy, transactions between associated enterprises are subject to rigorous statutory scrutiny to verify that pricing conforms to the arm’s length principle. Indian transfer pricing regulations require contemporaneous documentation, economic benchmarking, and independent accountant certification.

Sanjeev Dua & Associates assists commercial enterprises and multinational groups with transfer pricing documentation, economic benchmarking, Form 3CEB certification assistance, Master File compliance, and technical advisory during transfer pricing assessments.

Applicability

Who May Require This Service

General commercial circumstances and entity types subject to this framework.

Indian entities entering into commercial, financial, or service transactions with foreign associated enterprises.
Multinational groups with operational presence in India subject to multi-tier documentation requirements.
Corporate entities engaged in specified domestic transactions with related entities under tax-holiday provisions.
Enterprises undergoing transfer pricing scrutiny or seeking to establish defensible inter-company pricing policies.
Engagement Workflow

Typical Process & Engagement Approach

How our professional team coordinates and executes assignments.

1. Transaction Identification & Scoping

Identifying all cross-border and specified domestic transactions conducted with associated enterprises.

2. Functional, Asset & Risk (FAR) Analysis

Analyzing the commercial roles, assets deployed, and economic risks assumed by each participating entity.

3. Economic Benchmarking & Documentation

Selecting the most appropriate economic method and benchmarking transaction prices against comparable uncontrolled data.

4. Report Finalization & Certification Assistance

Compiling the transfer pricing study report and providing professional assistance with Form 3CEB filing.

Documentation

Information & Documents Typically Required

Standard records and background materials necessary for assessment and filing.

Inter-company agreements, service level contracts, and pricing memoranda
Segmental financial statements and detailed cost allocation sheets
Audited annual accounts of the Indian entity and relevant foreign associated enterprises
Invoices, debit notes, and documentation supporting cross-border management charges or royalties
Group organizational structure charts and global business profile descriptions
Methodology

Professional Approach & Standards

Our transfer pricing practice emphasizes economic substance and methodological rigor. We develop contemporaneous documentation that accurately mirrors operational realities and stands up to technical scrutiny during regulatory reviews.

Frequently Asked Questions

Common Questions

Key answers regarding service scope, regulatory relevance, and procedural steps.

What is the arm’s length principle in transfer pricing?

The arm’s length principle requires that prices, terms, and conditions agreed upon in transactions between associated enterprises correspond to what would have transpired between independent commercial parties in comparable uncontrolled circumstances.

What does Form 3CEB professional assistance involve?

It involves the independent examination and certification by a Chartered Accountant of the nature, quantum, and contractual terms of all international and specified domestic transactions entered into with associated enterprises during the financial year.

What information is typically captured in a Master File?

A Master File provides a high-level overview of a multinational group’s global business operations, organizational structure, supply chain, intangible property ownership, inter-company financing arrangements, and global tax positions.

Complementary Services

Related Practice Areas

Interconnected statutory and corporate advisory disciplines.

Income Tax Returns

Corporate income tax return preparation integrating transfer pricing adjustments and disclosures.

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Import-Export Consultancy

Cross-border trade code licensing and customs documentation aligned with international trade policy.

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Discuss Your Requirements with Our Office

Contact the firm to discuss your specific accounting, taxation, or compliance requirements with our professional team.

Contact Our OfficeView All Services