Transfer pricing documentation and Form 3CEB
When a company transacts with related parties abroad, prices must be at arm's length. Indian law requires documentation to support this, a chartered accountant's report in Form 3CEB, and in many cases a benchmarking study. We prepare all three and support you if the pricing is questioned in assessment.
What this covers
- Identification of international and specified domestic transactions
- Functional, asset and risk analysis
- Benchmarking with comparable companies
- Transfer pricing study report
- Form 3CEB accountant's report
- Support during transfer pricing assessments
The Income-tax Act, 2025 applies to income from 1 April 2026. Returns, audits and assessments for earlier years continue under the Income-tax Act, 1961, so section and form references depend on the year involved.
How the work is done
- Map related-party transactions for the year
- Analyse functions, assets and risks
- Select the method and run benchmarking
- Prepare documentation and certify Form 3CEB
Documents usually needed
- Intercompany agreements
- Related-party ledgers and invoices
- Audited financial statements
- Group structure chart
Frequently asked questions
Who needs to file Form 3CEB?
Every taxpayer that has entered into international transactions or specified domestic transactions with associated enterprises during the year.
What is the arm's length price?
The price that would be charged between unrelated parties in comparable circumstances.
Is a benchmarking study required every year?
Documentation must be maintained each year. Comparables are usually refreshed annually so the analysis reflects current data.