This book is an essential reference manual for ‘Legal Analysis’, ‘Practical Solutions’ & ‘Procedural Guidance’.

This book is written with the objective of strengthening the hands of Taxpayers and Professionals with the knowledge needed to meet the burden imposed by Domestic Transfer Pricing.

The Present Publication, authored by Nilesh Patel, is the latest edition, with the following noteworthy features:

·    [Legal Analysis] Covering the entire gamut of Domestic Transfer Pricing, where legal provisions are analysed at length and in-depth.

·    [Practice Solutions] 50+ Practical issues confronting Taxpayers, Professionals, Companies & Businesses are thoroughly explored. Practical solutions are also offered to the issues.

·    [Procedural Guidance] Complex concepts are explained with the help of Case Studies and simple examples. Besides, guidance is provided for these procedural aspects such as:

o   Functions, Assets and Risks (FAR) Analysis

o   Selection of Most Appropriate Method

o   Carrying out Comparability Analysis

o   Making Economic Adjustments

o   Preparing Transfer Pricing Study Report

o   Certifying Form 3CEB

·    Along with the Regulatory Analysis, content has been added in the form of Case Studies to help in every-day practice, management, compliance and planning, on three important aspects:

o   Functions, Assets and Risks (FAR) Analysis along with specimens of Transfer Pricing Study Reports & Checklists

o   Selection of the Most Appropriate Method for 35 Specified Domestic Transactions

o   Comparability Analysis involving the search for comparables in PROWESS and CAPITALINE

·    Chapter on Accountant’s Report in Form 3CED contains relevant content from ICAI Guidance Note on report under Section 92E of the Income Tax Act, 1961, which would be useful for Professionals in issuing From 3CEB.

·    Contents of this book are as follows:

o   Chapter 1 – Opening Remarks

o   Chapter 2 – Brief outline of provisions applicable to domestic transfer pricing

o   Chapter 3 – Specified domestic transactions

o   Chapter 4 – Domestic transfer pricing and Section 40A(2)(b); Issues

o   Chapter 5 – Domestic transfer pricing and Section 80A(6) or Section 80-IA(8); Issues

o   Chapter 6 – Domestic transfer pricing and Section 80-IA(10); Issues

o   Chapter 7 – Relevant transfer pricing provisions

o   Chapter 8 – Transfer pricing methods; General

o   Chapter 9 – Comparable uncontrolled price

o   Chapter 10 – Resale price method

o   Chapter 11 – Cost plus method

o   Chapter 12 – Profit split method

o   Chapter 13 – Transaction net margin method (TNMM)

o   Chapter 14 – Other methods

o   Chapter 15 – Functions, Assets and Risks (FAR) analysis

o   Chapter 16 – Most appropriate transfer pricing method

o   Chapter 17 – Case studies on most appropriate method for specified domestic transaction of payments to Section 40A(2)(b) persons

o   Chapter 18 – Case studies on most appropriate method for specified domestic transaction of inter-unit transfer of goods and services

o   Chapter 19 – Case studies on most appropriate method for specified domestic transaction of the kind described in Section 80-IA(10

o   Chapter 20 – Comparability analysis

o   Chapter 21 – Comparability adjustments

o   Chapter 22 – Documentation under transfer pricing regulations

o   Chapter 23 – Transfer pricing study report

o   Chapter 24 – Accountant’s report in Form 3CEB

o   Chapter 25 – Transfer pricing assessment

o   Chapter 26 – Dispute resolution and appeal

o   Chapter 27 – Penalties

o   Chapter 28 – Closing remarks