Form 3CEB certification
The accountant's report u/s 92E for international and specified domestic transactions — certified and filed by October 31.
Priced at arm's length. Defended all the way.
From the benchmarking study to Form 3CEB to the Tribunal — a complete transfer pricing practice under one roof.
The transfer pricing practice
Documentation built to survive scrutiny — and the team to defend it.
Every transaction with an associated enterprise must stand at arm's length — and the paperwork must prove it. The study, the benchmarking, the Form 3CEB: each piece is built to survive scrutiny, not just to meet the deadline. A file that merely gets filed and a file that holds up under examination are two very different documents.
Most TP disputes are lost at the documentation stage, years before anyone reaches a hearing — a thin FAR analysis or an indefensible comparable set decides the outcome long before an officer asks the first question. So we write documentation as if the TPO will read it, because eventually one will.
And when a matter does go to assessment, the same team that built the file defends it — through the TPO, the Dispute Resolution Panel and the Tribunal — so nothing is lost in handover between advisor and litigator. The people who chose the comparables are the people who argue for them.
At a glance
- Form 3CEB certification u/s 92E
- TP study & Rule 10D documentation
- Benchmarking — database comparables & method selection
- TPO assessment representation (Section 92CA)
- DRP objections within the 30-day window
- ITAT appeals & representation
- Safe harbour & Master File/CbCR advisory
What we handle
From the first comparable to the final hearing.
Compliance, documentation and litigation as one continuous practice — the file is built by the team that may one day have to defend it.
TP study & documentation
The Rule 10D file — FAR analysis, industry overview and method justification, written to be read by an officer, not just filed.
Benchmarking & comparables
Database searches with filters that survive scrutiny — TNMM/CUP/RPM/CPM/PSM selection and arm's-length range computation.
TPO representation
When a reference goes u/s 92CA — submissions, hearings and defence of the pricing before an adjustment hardens into an order.
DRP objections
The faster route past a draft order — objections drafted and argued before the Dispute Resolution Panel.
ITAT appeals
Grounds of appeal, paper-books and representation before the Tribunal — argued by the team that built the file.
Master File & CbCR
Forms 3CEAA/3CEAB and country-by-country reporting where group thresholds apply — mapped, prepared and filed on time.
Safe harbour & TP planning
Safe-harbour elections, intercompany agreements and pricing policies set before the year runs — not reconstructed after it.
How a TP engagement runs
Four steps from mapping to a defended position.
01
Map
Associated enterprises identified, transactions listed, functions, assets and risks analysed — the shape of the file before a single number is benchmarked.
02
Benchmark
The most appropriate method selected, comparables screened through defensible filters, and the arm's-length range computed.
03
Document & certify
The Rule 10D study finalised, Form 3CEB certified and filed by October 31 — a file built to be read, not just submitted.
04
Defend
TPO submissions, DRP objections, ITAT appeal — whichever stage a matter reaches, the same team carries it end to end.
Common questions
Transfer pricing questions, answered plainly.
Every enterprise that has entered into international transactions with associated enterprises must file Form 3CEB — there is no minimum threshold. Specified domestic transactions require the form once they cross ₹20 crore in a financial year. The form is due by October 31 following the financial year, and the income-tax return for transfer-pricing cases is due November 30.
In plain English: we pick the most appropriate method (TNMM is the most common), search databases for comparable companies, apply quantitative and qualitative filters to that list, compute the arm's-length range, and document why each choice was made. The defensibility lives in the filters — a study is only as strong as the reasoning behind which comparables stayed in and which were rejected.
The case is referred to the Transfer Pricing Officer under Section 92CA, who issues a questionnaire and holds hearings — and may propose an adjustment that lands in a draft order. From there you choose a route: file objections before the Dispute Resolution Panel within 30 days (the Panel decides, and the assessment is finalised after its directions), or take the CIT(A) route after a final order. Either way, the ITAT sits above as the next stage — and we handle the full chain.
Failure to furnish Form 3CEB attracts a penalty of ₹1,00,000 under Section 271BA. Failure to keep or report the prescribed documentation can cost 2% of the transaction value under Sections 271AA and 271G — and any adjustment carries tax plus interest on top of it. Against numbers like those, the documentation is cheap insurance.
Yes — if you transact with a foreign associated enterprise, there is no materiality exemption from the Form 3CEB requirement. But proportionate approaches exist: safe harbour elections can simplify the exercise, and documentation can be lean but complete. We scale the work to the size of the risk, not the other way round.
Have a deadline, a notice, or a plan to grow?
Get a clear answer on where you stand and what to do next — usually within one working day.