Our TP services begin with an in-depth functional analysis identifying the roles, risks, and assets of each related party involved in the transaction. Based on this analysis, we select the most appropriate pricing method (TNMM, CUP, CPM, etc.) in alignment with Indian TP rules and OECD guidelines.

We develop a robust Transfer Pricing Study Report (TPSR) containing benchmarking studies, comparables analysis, economic adjustments, and justification for pricing decisions. This documentation helps prevent adjustments, litigation, and penalties in case of audits or scrutiny from tax authorities.

Our team assists with the preparation and timely submission of Form 3CEB, mandatory for international transactions above specified thresholds. We also advise on Master File and Country-by-Country Reporting (CbCR) requirements applicable to large MNE groups under the BEPS framework.

In addition to compliance documentation, we offer TP planning and strategy services helping businesses set appropriate transfer prices, design intercompany agreements, and align TP policies with commercial realities.

Our Transfer Pricing professionals include chartered accountants and legal experts who stay updated with changes in global and Indian TP rules, helping clients navigate the increasing scrutiny and regulatory complexity with confidence.

• Including benchmarking, FAR analysis, method justification, and comparables.

• Precise reporting of international and specified domestic transactions.

• Using recognized TP databases and statistical tools.

• For multinational groups exceeding global thresholds under Rule 10DA/10DB.
• Strategic support in applying and negotiating bilateral/unilateral APAs.
• Structuring intercompany pricing models to avoid future tax disputes.
• End-to-end assistance in responding to audits, TP adjustments, and appeals.

We don’t believe in one-size-fits-all auditing. At Pawan Lohia & Associates, every Risk-Based Internal Audit begins with an in-depth understanding of your business model, industry dynamics, and regulatory exposure. Our team collaborates closely with your internal stakeholders to prioritize risk areas, define scope, and execute detailed audits with a strategic lens.