India Transfer Pricing
India is one of the supported jurisdictions — the s.92 framework, the Rule 10D/10DA documentation, the section 92CB safe harbours, the TDS on the payments, the ETP side and the MAP route, in one sub-hub.
India Transfer Pricing: The Complete s.92 Overview (2026)
The Indian transfer pricing framework end to end: section 92 and its sub-sections, the Rule 10B methods, the documentation tiers, the thresholds, the penalties and the TPO.
Read docRule 10D and 10DA Deep Dive: Local File and Master File Requirements
The Indian documentation rules rule by rule: Rule 10D’s Local File blocks, the 30-day preparation window and the 282BC production; Rule 10DA’s Master File and its maintain-and-produce obligation.
Read docRule 10AA and 10AB Safe Harbours in India: Conditions and Strategy
The Indian service safe harbours’ jurisdiction mechanics: Rule 10AA’s intra-group services harbour and Rule 10AB’s KPO/ITES tiering, their conditions, and how they sit in the current Rule 10TD regime.
Read docTDS on Transfer Pricing Payments: Interest, Royalty, Service Fees
The withholding character and rates on intra-group payments — interest, royalty, technical and management fees — the DTAA interplay, the royalty-versus-service dispute, and the compliance mechanics.
Read docExternal Transfer Pricing (ETP): Inbound Investors’ Playbook
ETP from the investor’s side: pricing the inbound investment — the share purchase, the technology, the capital — the TPO’s examination of the Indian position, and the investor’s documentation.
Read docMAP and DTAs in India: Resolving Double Taxation After an Adjustment
The mutual agreement procedure in India: the MAP rules, the DTA network, the application, the timelines, the correlative adjustment — and the practical outcomes for the adjusted taxpayer.
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Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.