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Transfer Pricing

Transfer Pricing Services & Consultant in Delhi

End-to-end transfer pricing support for companies with related-party or cross-border transactions — advisory, benchmarking, documentation, Form 3CEB compliance and dispute support.

TP AdvisoryBenchmarkingDocumentation3CEB & Litigation
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Trusted Across Diverse Business Sectors

Gerresheimer
Leverage
Bureau Veritas
Ultrasyst Systems
UFLEX
Meitra Hospital
IRUS
JJJ Client
Kidys Bakery
MK Engineering Works
Bhanu Biotech
Saish Medical Solutions
Bio Petro Clean
Kartik Speciality Coatings
Delta Bioscience
Transfer Pricing Overview

Where does transfer pricing support fit for a group?

Transfer pricing covers every stage of related-party dealings — from setting the pricing policy to benchmarking, documenting, certifying and, if needed, defending it.

Compliance & Documentation

The annual cycle of studying, documenting and certifying related-party transactions.

  • Benchmarking study
  • TP documentation
  • Form 3CEB certification

Advisory & Defence

Setting policy up front and defending positions in assessment or appeal.

  • Intercompany pricing policy
  • Risk assessment
  • Representation and litigation
Important: The right workstream depends on the transactions, the group structure and the stage of the year or dispute.
Transfer Pricing Perspective

Transfer pricing is decided by the transaction, tested by comparables.

Wherever a company transacts with a related party — goods, services, funding, intangibles — the price must reflect what independent parties would charge, the arm's-length principle.

That position is set by a pricing policy, tested against comparable data, recorded in documentation and certified in Form 3CEB.

Groups therefore need a combination of advisory, benchmarking, documentation and dispute support rather than certification alone.

Transfer Pricing Workstreams

Use this overview to identify the service that matches the need.

Pricing Policy
Risk Assessment
Benchmarking
Documentation
Form 3CEB
Litigation Support
Transfer Pricing Coverage

Choose the transfer pricing workstream that matches the need.

The services below are separate assignments and can also be combined across the compliance and dispute cycle.

TP Advisory & Policy

Setting and reviewing arm's-length pricing policies for the group.

Benchmarking Study

Selecting comparables and testing margins against market data.

Documentation & 3CEB

Preparing the TP study and certifying transactions in Form 3CEB.

Representation & Litigation

Defending positions before the TPO and appellate forums.

When Transfer Pricing Support Matters

Events that change the transfer pricing position.

New Related-Party Transactions

Pricing, benchmarking and documentation must be set up.

Foreign Parent or Subsidiary

Cross-border dealings bring TP obligations and scrutiny.

Intangibles or Financing

Royalties, IP and intra-group loans need careful analysis.

TP Notice or Adjustment

The position must be defended with data and documentation.

Transfer Pricing Framework

Key areas that shape transfer pricing analysis.

Arm's Length

Principle

Related-party prices must match those between independent parties.

Method

Selection

The most appropriate method is chosen for each transaction type.

Comparables

Benchmarking

Independent comparable data tests whether pricing is at arm's length.

Form 3CEB

Certification

Related-party transactions are reported and certified each year.

How We Work

A practical transfer pricing cycle from policy to defence.

The process changes depending on whether the work is advisory, compliance or litigation.

01

Map

Identify related parties, transactions and the group structure.

02

Analyse

Select methods and characterise each transaction.

03

Benchmark

Test pricing against comparable independent data.

04

Document

Prepare the TP study and certify in Form 3CEB.

05

Defend

Support the position in assessment or appeal where needed.

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Information Required

What should your finance team prepare?

Group structure and related parties
List of related-party transactions
Agreements for each transaction type
Segmental financials where available
Prior TP study and Form 3CEB
Details of intangibles or financing
Any TP notices or adjustments
Functional and risk information
Risk & Consistency

The best transfer pricing position is consistent, benchmarked and documented.

An unsupported price can trigger adjustment, tax, interest and penalty; an inconsistent one across years invites scrutiny.

Benchmarking and documentation are what convert a policy into a defensible position at assessment.

The strongest model sets policy up front and maintains documentation year on year, rather than reconstructing it under notice.

Need a combined transfer pricing review across compliance and defence?

Discuss Transfer Pricing
Transfer Pricing Consultant in Delhi

Why groups work with JJJ & Company LLP for transfer pricing.

Transfer pricing works best when policy, benchmarking, documentation and defence connect.

Transaction-Led Analysis

Advice starts with the actual related-party dealings and functions.

Robust Benchmarking

Comparables are selected and tested with discipline.

Documentation to Defence

Study and 3CEB are built to hold up under scrutiny.

Cross-Border Context

TP is considered alongside international tax and FEMA.

Frequently Asked Questions

Common transfer pricing questions.

Which companies need transfer pricing compliance?
Any company entering into international transactions with associated enterprises, and specified domestic transactions above thresholds, generally must comply and file Form 3CEB.
What is the arm's-length principle?
It requires related-party transactions to be priced as they would be between independent parties, tested using prescribed methods and comparable data.
Can advisory, documentation and defence be combined?
Yes. A single engagement can set policy, prepare benchmarking and documentation, certify 3CEB and support any later dispute.
What is Form 3CEB?
It is the accountant's report certifying a company's international and specified domestic related-party transactions, filed annually.
What triggers a transfer pricing adjustment?
Prices not supported as arm's length, weak documentation or inconsistent positions can lead the officer to propose an adjustment.
How often should documentation be prepared?
Transfer pricing documentation is prepared annually, aligned with the year's transactions and Form 3CEB.
Reviewed by JJJ & Company LLP Chartered Accountancy Team · Last reviewed: August 2026
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