In Transfer Pricing Audit, a Chartered Accountant is required to comment on pricing of transactions between two or more associated enterprises vis- vis also commenting on Arm’s Length Price by applying any of the following most appropriate method prescribed under Transfer Pricing regulation:

  • Comparable Uncontrolled Price Method
  • Resale Price Method
  • Cost plus Method
  • Profit Split Method
  • Transactional Net Margin Method


The taxpayer may choose any method which is most appropriate based on the facts and circumstances in his case.


The Applicability of Transfer Pricing can be better understood from following chart:

Particulars International Transfer Pricing Domestic Transfer Pricing
  I. On a transaction (sale, purchase, lease) between two or more associated enterprises in which either or both of them are non- residents.
I. On any expenditure in respect of which payment is made or to be made u/s 40A(2)(b).
II. On any transaction mentioned in section 80A.
Applicability  II. On any other transaction having a bearing on profits, income, losses including any agreement / arrangement entered into for allocation or apportionment of any cost or expense.
III. On any transfer of goods or services u/s 80-IA(10).
IV. On any business transacted between the assessee and other person u/s 80-IA(8) and 80-IA(10).
V. On any transaction referred to in any other section under chapter VI-A or section 10AA, to which provisions of sec 80-IA(8) and 80IA(10) are applicable.
Relevant Form to be filed Form No. 3CEB u/s 92E Form No. 3CEB u/s 92E
Relevant Due Date For Compliance 30th November 30th November
Due Date For Tax Audit 30th November 30th November
Due Date For Return 30th November 30th November
Monetary Limit No Monetary Limits Companies having related party transactions more than 5 Crore


We can assist you in:

  • Determining the Arm Length Pricing.
  • Preparation of Transfer Pricing Report.
  • Conducting Transfer Pricing Audit.
  • Representation before taxing authorities.