Transfer Pricing Review

Transfer pricing in India has matured into one of the most heavily litigated areas of tax, and the authorities scrutinise intercompany transactions closely. Cross-border service fees, royalties, intra-group financing, the sale of goods between associated enterprises, cost-sharing arrangements, and management charges all attract attention, and each must be benchmarked against what independent parties would have done. Our team reviews your transactions against the prescribed methods, tests the arm’s-length range, and identifies where your pricing is exposed before a transfer pricing officer reaches the same file.

The documentation is where cases are won or lost, and it is exactly where Law Mahaguru’s rigour shows. We help build and review the local file, the functional analysis that explains who in the group does what, bears which risks, and owns which assets, and the benchmarking that supports your pricing. We also advise on the master file and country-by-country reporting obligations for groups that cross the relevant thresholds. Sound documentation does not merely satisfy a compliance requirement; it is the shield that deters an adjustment in the first place.

Where a position is genuinely uncertain, we help you weigh the available protections, including advance pricing agreements that lock in a method with the authorities, and the safe-harbour options where they apply. And where an adjustment has already been proposed, our legal grounding lets us frame the response and the dispute strategy on the law and the facts together, rather than on benchmarking alone.

Our clients include Indian subsidiaries of multinational groups, Indian companies with overseas arms, and businesses preparing for or responding to a transfer pricing assessment. Each receives a clear-eyed review of where their related-party pricing stands and what it would take to defend it.

Transfer pricing is not a place for optimism; it is a place for preparation. Law Mahaguru gives you the review and the documentation that turn a high-risk area into a defensible one. Tell us about your intercompany transactions, and we will show you where you stand and how to make your position hold.