International Transfer Pricing


Ahuja & Ahuja provides advisory services regarding international transfer pricing which helps in effective operation of your business in India. We help our clients in countering the new Transfer Pricing Regulation in a cost-effective manner, without consuming much time. We provide appropriate solution to our clients after studying their business objectives and the nature of transactions that have been carried out.


The following step-by-step procedures explain our modus operandi.


  • A fact-finding exercise is carried out in order to analyze the various functions performed by the organization and the possible risks that can be encountered by each activity.
  • Select the appropriate method of transfer pricing and identify the parties who have been tested with the particular method.
  • Conduct a survey based on the database available from various national and international sources in order to identify the companies that can be benchmarked for the selected company and perform a financial analysis on the basis of them.
  • Prepare a consolidated report on the basis of the analysis and document it appropriately.
  • Issue the report in Form 3CEB as mandated by the Indian Income Tax Act, 1961.


More About Transfer Pricing Regulation


Transfer Pricing Regulation was introduced with a view to provide a detailed statutory framework which can lead to computation of reasonable, fair and equitable profits and tax in India, in the cases of multinational enterprises, and also introduced new s 92A to 92F in the Act, relating to computation of income from an international transaction having regard to the arm’s length price, meaning of associated enterprise, meaning of international transaction, computation of arm’s length price, maintenance of information and documents by persons entering into international transactions and definitions of certain expressions occurring in the said sections.


Transfer Pricing Regulations
The Transfer pricing Regulations (TPR) were introduced in India vide the Finance Act, 2001 by substitution of the existing 92 and introduction of new sections 92A to 92F in the Income Tax Act (‘Act’) and relevant rules 10A to 10E in the Income Tax Rules, 1962. The regulations are applicable to relevant international transactions entered into from 1st April 2001.


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