Chartered Accountants in India, working with clients across the UK

Transfer Pricing Assessment
Transfer Pricing · Assessment

Transfer pricing assessment:defending your prices.

When an Indian entity's return is selected for scrutiny, its international transactions may be referred to a Transfer Pricing Officer. The TPO asks for documents, tests the prices and can propose an adjustment. We prepare the submissions, answer the questions and argue the case so adjustments are avoided or kept low.

Submissions preparedFees agreed in writingHearings handled
OfficerTransfer Pricing Officer
Key evidenceDocumentation and agreements
RiskAdjustment and penalty
DefenceStrong submissions

How a TP assessment runs.

01
Select

Scrutiny

The return is selected and the case referred to the TPO.

02
Ask

Notices

The TPO asks for documentation, agreements and evidence.

03
Test

Analysis

The TPO tests comparables, methods and charges.

04
Propose

Show cause notice

Any proposed adjustment, with time to reply.

05
Order

TPO order

Passed by a fixed date; then a draft or final assessment order.

Old and new section numbers

From 1 April 2026 the Income-tax Act, 2025 has renumbered the transfer pricing provisions. Cases for years before tax year 2026-27 still run under the Income-tax Act, 1961, so this page uses the familiar section numbers. We apply whichever Act covers your year.

What TPOs focus on.

Margins

Service and support margins

Comparables, filters and the arm's length range.

Charges

Management fees and royalties

Evidence that services were received and benefited India.

Finance

Loans and guarantees

Interest rates, guarantee fees and outstanding receivables.

Intangibles

Marketing and technology

Use of brands and know-how without payment.

Penalties to watch.

An adjustment can lead to penalty for under-reporting or misreporting, and missing documents bring separate penalties. Good documentation is the main protection. See Transfer Pricing Documentation and Section 270A.

Why UK companies choose us in India.

We speak UK and India

We work with your UK finance team, lawyers and auditors, and translate Indian requirements into plain English.

Reviewed before filing

Every filing and certificate is checked by a second Chartered Accountant before it goes in.

Fees agreed in writing

A written scope, timetable and fee before work starts.

A compliance calendar

One calendar of every MCA, RBI, GST and income-tax deadline for your Indian entity.

One team end to end

Set-up, accounts, payroll, tax, audit and RBI filings handled together.

Secure and fully online

Encrypted document sharing and digital signatures. Directors never need to travel.

TP assessment support for UK groups.

We support UK groups headquartered anywhere in the UK with transfer pricing for their Indian subsidiaries and branches, working with their UK tax teams online.

London

City of LondonCanary WharfHarrowWembleySouthallHounslowIlfordEast HamCroydonEdgware

South East

ReadingSloughMilton KeynesOxfordWatfordLutonCrawleyGuildford

Midlands

BirminghamLeicesterCoventryNottinghamWolverhamptonDerbyNorthampton

North of England

ManchesterLeedsBradfordSheffieldLiverpoolNewcastlePreston

East and South West

CambridgePeterboroughBristolSwindonSouthamptonBath

Scotland, Wales, NI

EdinburghGlasgowAberdeenDundeeCardiffSwanseaBelfast

Transfer pricing assessment FAQs.

A specialist officer who examines transactions with associated enterprises referred to them.
Documentation, agreements, invoices, benchmarking and proof of services.
Often, with strong documentation and well-argued submissions.
A draft order for DRP-eligible companies, or a final order appealable to the CIT(A).

Facing a transfer pricing assessment?

Send us the notice. We will plan the submissions and the defence.

This page is general guidance based on the Income-tax Act, 2025 and the rules and return forms as they stand. It is not legal or financial advice for your situation. Forms, eligibility and due dates can change each year, so please check with us before filing.