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TP

Transfer pricing · Form 3CEB

Authority: Income Tax TP officers · CA report

Buying from or paying royalties, fees or interest to the Korean parent must be at arm's length. A CA-certified Form 3CEB is filed and documentation kept; it's the most audited area in India.

What to do

Official: confirmed from the law, government notifications and expert sources · Case-specific: whether or how much it applies depends on your company; Adullam assesses it for you in consultation · Example: illustrative only.

AnnualOfficial

Purchases, sales, royalty, technical and management fees, loans, guarantees and recharges with group entities.

Source: adullamcorp.com · checked
AnnualOfficial

CA report by 31 October; the 2026 audit extension doesn't apply. From Tax Year 2026-27 it is filed as Form 48.

Source: vidur.in ·
AnnualOfficial

By 30 November.

Source: taxguru.in · checked
AnnualOfficial

An annual comparables study; detailed documentation is required once international transactions exceed ₹1 crore.

Source: calcguru.in ·
AnnualOfficial

Groups with revenue above ₹500 crore and international transactions above ₹50 crore (₹10 crore for intangibles) also file a master file (Form 3CEAA).

Source: calcguru.in ·
As neededCase-specific

Large deals between Indian group entities can be covered when specific conditions apply, such as tax incentives. Adullam reviews your structure to decide.

Source: incometaxindia.gov.in · checked
As needed

Respond to TP officer queries and adjustments.

Source: adullamcorp.com · checked

Deadlines


Source: adullamcorp.com · checked
Adullam

Source: adullamcorp.com · checked
Partner CA

Source: vidur.in ·
Income tax

Source: taxguru.in · checked
Income tax

What we need from you

  • Intercompany agreements
  • Invoices and remittances per transaction
  • How HQ sets prices
  • Functions and risks of the Indian entity

Good to know

A royalty to the parent touches TP, withholding (10% treaty), GST reverse charge and remittance forms (145/146, old 15CA/15CB) — the numbers must agree everywhere.

Source: incometaxindia.gov.in · checked

Penalties & interest

₹1 lakhOfficial Source: treelife.in ·
2% of the transaction value (s.457)Official Source: incometaxindia.gov.in · checked
Tax plus interest on the adjustment, and possibly a penalty; amounts depend on the adjustmentCase-specific Source: treelife.in ·

Our fees

Example: ₹50,000–₹3 lakh by transaction typesExample
Example: 3–6 weeks once data is inExample

Recent cases

Confirmed cases plus illustrative examples within real ranges; examples are labelled.

· Adullam client listOfficial

Joongwon E&C prepared its TP report with Adullam, documenting parent technical support and secondee costs.

Read source →
Example

After a 15% transfer-price increase the Indian margin fell below comparables; documenting the reason reduced adjustment risk.

Request a consultation

Are any of our Indian filings missing?

Our local accounting team and partner chartered accountant will look with you. The first consultation is free.

Phone+82-10-7641-4018
KakaoTalkceo_adlconsulting
Emailliminae@adullamcorp.com
WhatsApp+82-10-2991-4018
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Common questions with sources. Our AI answers from the material we have prepared.

Transfer pricing · Adullam Tax & Accounting