Transfer Pricing in
Uttar Pradesh

IMAK Advisory is an ICAI-registered firm of chartered accountants in Whitefield, Bengaluru, working with Indian subsidiaries of foreign groups, captive and global capability centres, Indian groups with overseas companies and startups owned by foreign holding companies. We plan intercompany pricing, prepare the functional analysis and benchmarking, keep the documentation the law requires and certify the accountant's report, so that prices between group companies can be defended in an assessment.

What is transfer pricing? It is the price charged between associated enterprises – companies under common control – for goods, services, intangibles, loans and guarantees. Indian law requires these prices to be at arm's length, the price unrelated parties would agree in similar conditions, tested by the most appropriate of six methods: comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin and other method. Where there are six or more comparables, the arm's length range is the 35th to 65th percentile.

From tax year 2026-27, the rules sit in Chapter X of the Income-tax Act, 2025, and the accountant's report Form 3CEB becomes Form 48, due one month before the return due date. Documentation is needed where international transactions exceed ₹1 crore in the year, and specified domestic transactions are covered above ₹20 crore. Large groups also check master file and country-by-country reporting.

The Union Budget 2026-27 merged software, IT-enabled, knowledge process and related contract research services into one safe harbour category with a common 15.5% margin and a ₹2,000 crore threshold, approved through an automated process for up to five years, and announced a fast-track advance pricing agreement process for IT services. A block option also lets one year's arm's length price apply to the next two years when facts do not change.

Most disputes start with missing agreements, copied functional analyses, weak comparables and no evidence that group services were received. Checking these each year, along with customs, GST and remittance papers, keeps the positions consistent across authorities.

For a new Indian subsidiary, transfer pricing work should be done before the first invoice: a signed intercompany agreement, a pricing policy based on a benchmarking study, a monthly invoicing routine and a simple tracker of every transaction with group companies, including reimbursements, guarantees and share issues. This costs far less than defending a first-year adjustment, and it gives the group's auditors and the foreign tax authority the same answer as the Indian tax department.

If the case is selected for assessment, the documentation, the comparable search and the reasons for rejecting other companies become the evidence. We prepare the replies, defend the method and the comparables before the officer, and use the Dispute Resolution Panel, appeals or a mutual agreement procedure under the tax treaty where they suit the facts.

We do not choose comparables to reach a pre-decided margin, and we work with advocates where a matter reaches the Tribunal or courts. We do not publish fees; our team shares the exact total after reviewing your requirements. Visit us at ITPL Main Rd, Pattandur Agrahara, Whitefield, Bengaluru, Karnataka 560066, call or WhatsApp +91 79798 50684, or email imakadvisoryteam@gmail.com, and the IMAK Advisory team will review your group transactions and plan the year's compliance.