Transfer Pricing Documentation

Compliant, defensible, and expertly drafted transfer pricing reports that stand up to scrutiny.

100+
transfer pricing studies
110+
total international transaction
95%
audit success rate
72hrs
draft review turnaround
Overview

Navigate Transfer Pricing With Confidence

In a Better Regulated Financial Environment

Cross-border transactions between related parties invite scrutiny under India’s Transfer Pricing regulations. Accurate documentation is not just a compliance requirement under Section 92D—it’s your first line of defense in case of audits or adjustments.

At CA Lekshmi & Associates, we provide comprehensive transfer pricing documentation including Local File, Master File, and benchmarking reports tailored to your industry, business model, and transaction profile. Our team ensures your documentation is robust, risk-rated, and ready for assessment proceedings.

Avoid pricing disputes, show clear intent, and protect your profits—legally and globally.

Who we serve

Transfer Pricing Documentation Services We Offer

  • Local File Preparation – Transaction analysis, FAR (Functions, Assets & Risks) profiling, and economic justification

  • Benchmarking Analysis – Arm’s Length Price (ALP) determination using suitable methods (CUP, TNMM, etc.)

  • Master File Preparation (Form 3CEAA) – Global group structure, intangible ownership, and financial overview

  • Form 3CEB Filing – Chartered Accountant-certified disclosures of international transactions

  • Audit Defense & TP Risk Assessment – Strategic support in scrutiny or audit cases involving TP adjustments

Includes transaction mapping, economic research, documentation drafting, and compliance filing.

Commitment

Precision-Driven, Audit-Ready Transfer Pricing

Inaccurate or incomplete documentation can trigger audits, penalties, and prolonged litigation. Proactive transfer pricing documentation not only protects your business but also builds investor confidence and operational transparency across borders.

Our Process

Compliant, timely, and tailored to your group structure

  • Transaction Mapping & Entity Profiling
    Understand the nature, scope, and context of intercompany transactions.

  • Functional, Asset & Risk Analysis (FAR)
    Evaluate each party’s contribution to value creation in the transaction.

  • Benchmarking Study
    Conduct arm’s length price comparison using global/local databases.

  • Documentation Compilation
    Preparation of Local File, Master File, and (if applicable) Country-by-Country Report.

  • Review & Filing Support
    Guidance on reporting obligations and audit readiness.

Who we serve

Driving Global Compliance for Indian Entities

Subsidiaries

Ensure transactions with parent companies are priced fairly and defensibly.

Startups with Foreign Capital

Stay compliant from day one when raising or repatriating funds across borders.

Service Providers

TP studies for offshore contracts, inter-company services, and shared costs.

Exporters

Determine ALP for goods or IP licensed between related parties.

FAQ

Transfer Pricing Documentation FAQs

Common questions about income tax, compliance, and litigation support in India.

It refers to pricing of transactions between related parties across borders. The law requires documentation to ensure they are conducted at Arm’s Length—like any third-party deal.

Any Indian company or entity entering into international transactions with related parties exceeding prescribed thresholds.

Non-compliance may lead to penalties and TP adjustments, increasing your taxable income. We ensure everything is filed on time and error-free.

We use methods like CUP (Comparable Uncontrolled Price), TNMM (Transactional Net Margin Method), and Resale Price Method, depending on your business and transaction type.