Transfer Pricing Advisory & Compliance
Understand Indian transfer pricing provisions (Sections 92–92F of the Income-tax Act).
Apply the Arm's Length Principle (ALP) to international and specified domestic transactions.
Prepare Transfer Pricing Documentation and Form 3CEB.
Conduct benchmarking studies and select the most appropriate transfer pricing method.
Benchmarking & Comparable Analysis
Use databases such as Prowess and Capitoline to identify comparable companies.
Perform functional, asset, and risk (FAR) analysis.
Prepare Accept/Reject matrices for comparable companies.
Compute profit level indicators (PLIs) and margins using filters such as:
Related Party Transactions (RPT)
Turnover
Employee cost
Export revenue
Persistent losses
Litigation & Assessments
Handle proceedings before the Transfer Pricing Officer (TPO).
Draft replies to notices issued by tax authorities.
Prepare submissions before the Dispute Resolution Panel (DRP).
Draft appeals before appellate authorities and attend hearings.




Review assessment orders and recommend further action.
Tax Compliance
Prepare and review:
Form 3CEB
Tax audit reports under Section 44AB
Corporate tax-related certifications
Ensure compliance with transfer pricing and direct tax regulations.
Research & Technical Analysis
Research transfer pricing provisions, judicial precedents, CBDT circulars, and OECD Guidelines.
Analyze complex business transactions.
Prepare technical memoranda and opinions for partners and clients.
Client Management
Understand client business models and related-party transactions.
Collect information and documentation through detailed checklists.
Coordinate with clients for timely submission of information.
Provide regular updates on assessments and litigation matters.
Build solid client relationships through timely and high-quality service.
Team Coordination
Guide articles and junior team members.
Review resear

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