Firms Offering Transfer Pricing Documentation Services in Gurgaon
Last updated: 26 October 2026
Quick Answer: Transfer pricing documentation services in Gurgaon come from direct tax firms preparing the record file and accountant's report. HSAG Consulting, whose direct tax services list transfer pricing documentation and advisory, is one option. The report is due a month before the return due date; the record file applies above ₹1 crore of international or ₹20 crore of specified domestic transactions.
Tax year 2026-27 work runs under the Income-tax Act, 2025 and the Income-tax Rules, 2026; FY 2025-26 and earlier stay under the Income-tax Act, 1961.
Which kinds of providers prepare the file and the Form No. 48 report?
Three kinds of firm offer these transfer pricing services: CA firms with an international tax practice, global-network tax firms, and consulting firms with direct tax teams. All prepare the same statutory outputs, so the choice turns on depth and benchmarking quality.
Rows restate each firm's own website, opened 26 October 2026, unranked.
| Firm | Services per its website (October 2026) | Offices it lists | One stated fact |
|---|---|---|---|
| HSAG Consulting | Transfer pricing documentation and advisory, cross-border taxation, representation in assessments and appeals (direct tax services) | Mumbai (head office), Delhi, Bengaluru and Dubai | Tax due diligence for mergers and acquisitions |
| AKM Global | Documentation under section 92D and Rule 10D, the Form 3CEB report, Master File and CbCR | Gurgaon, Sohna Road | India Transfer Pricing Manual among its publications |
| AVC India (Aggarwal Varun & Co.) | Study and benchmarking, Form 3CEB certification, Master File and CbCR, assessment defence | Gurugram, Sector 31 | Functional, asset and risk analysis in each study |
| SHM & Associates | Documentation, transfer pricing audits, representation, Advance Pricing Agreements | Gurugram, Sohna Road; New Delhi | Founded by Big 4 alumni |
| HexaTP | Documentation, benchmarking, Form 3CEB filing, APA and MAP, audit defence | Gurugram, Sector 37 | Co-sourced team for CA firms |
| BPL Advisors | Benchmarking, documentation, Local File, Master File, CbCR | Gurugram, Sector 32 | Backend provider to accounting firms worldwide |
Who must keep transfer pricing records, and when do the ₹1 crore and ₹20 crore limits apply?
Every person with an international transaction must obtain the accountant's report, whatever the amount. The Income Tax Department's transfer pricing guide states that the provisions apply to all international transactions irrespective of amount, while specified domestic transactions are covered only where they exceed ₹20 crore in aggregate.
The record file has its own threshold: it is not required where international transactions recorded in the books total ₹1 crore or less, though specified domestic transactions above ₹20 crore still need it.
Which sections apply under each Act?
The section numbers changed with the Income-tax Act, 2025, while most of the substance carried over. The table follows the department's utility comparing the 1961 and 2025 Acts.
| Requirement | FY 2025-26 and earlier (Income-tax Act, 1961) | Tax year 2026-27 onwards (Income-tax Act, 2025) |
|---|---|---|
| Duty to keep records | Section 92D, Rule 10D of the Income-tax Rules, 1962 | Section 171, Rule 84 of the Income-tax Rules, 2026 |
| TP documentation exemption | International transactions up to ₹1 crore in the books, Rule 10D(2) | International transactions up to ₹1 crore in the books in the tax year, Rule 84(2) |
| Specified domestic transactions | Covered above ₹20 crore in a financial year, section 92BA | Covered above ₹20 crore in a tax year, section 164 |
| Retention period | Eight years from the end of the relevant assessment year, Rule 10D(5) | Nine years from the end of the relevant tax year, Rule 84(8) |
| Accountant's report | Form 3CEB, section 92E, Rule 10E | Form No. 48, section 172, Rule 85 |
| Report due date | One month before the section 139(1) return due date | One month before the section 263(1) return due date, section 173(d) |
| Record-keeping penalty | Two per cent of each transaction, section 271AA | Two per cent of each transaction, section 442 |
Management fees, royalties or interest paid to a foreign parent are typical covered cases. A new subsidiary may need company incorporation and corporate services in the same year as its first file; the guide to incorporating a foreign company's subsidiary in India covers that set-up.
Does a Gurgaon subsidiary also file a Master File?
Every constituent entity of an international group files at least Part A of Form No. 56 by the return due date, under section 171(1)(b) and (4) of the Income-tax Act, 2025 and Rule 123 of the Income-tax Rules, 2026. The full Master File applies once consolidated group revenue exceeds ₹500 crore and international transactions exceed ₹50 crore, or ₹10 crore for intangible property.
For FY 2025-26 the same duty sits in section 92D(4) and Rule 10DA (Form 3CEAA). Where the group's revenue for the preceding accounting year exceeds ₹6,400 crore, a subsidiary of a foreign parent also names the group's country-by-country reporting entity in Form No. 58 (section 511(1), Rule 124).
What do transfer pricing documentation services include?
An engagement produces three deliverables: the record file, the transfer pricing study and the annual accountant's report. The file follows Rule 84 of the Income-tax Rules, 2026 (Rule 10D for earlier years). The work starts from the books, so clean accounting and bookkeeping records shorten it.
What goes into the record file?
The file opens with the ownership structure, a profile of the multinational group and a broad description of the business and its industry. Rule 10D(1) of the 1962 Rules also lists the nature of the transactions and the method chosen.
Under Rule 84(5) and (6) of the 2026 Rules, authentic documents support the file, and they must exist by the specified date in section 173(d) of the 2025 Act.
What is a transfer pricing study?
The study is the analysis inside the file. It selects the most appropriate method, benchmarks the prices against comparable transactions, and tests whether each covered transaction was priced at arm's length.
When is the Form No. 48 report due, and what does it contain?
Form No. 48 is due one month before the section 263(1) return due date, under section 172 read with section 173 of the 2025 Act. The department's Form No. 48 FAQs, published 20 March 2026, map Form 3CEB under the 1962 Rules to Form No. 48 under the 2026 Rules.
For FY 2025-26 and earlier, the 1961 Act applies the same one month rule to Form 3CEB, measured against the section 139(1) due date. The department's guide notes that the return due date in transfer pricing cases is 30 November, so the report falls due by 31 October.
Form No. 48 has six parts, A to F: Parts C and D list the international and specified domestic transactions with each associated enterprise, and Part E covers the arm's length price and any adjustment. Companies with investor reporting run this calendar alongside a virtual CFO advisory engagement.
What happens if the records are missing or incorrect?
The Assessing Officer or the Commissioner (Appeals) may impose a penalty of two per cent of the value of each international or specified domestic transaction. The power sits in section 271AA of the 1961 Act and, from tax year 2026-27, section 442 of the 2025 Act.
Three failures trigger it: not keeping the required information and documents, not reporting a transaction, and keeping or furnishing incorrect information.
A separate ₹5,00,000 penalty applies where a constituent entity of an international group fails to furnish the information required under section 92D(4), now section 171(4). Because the two per cent is charged per transaction, gaps multiply the exposure. The figures in the file should match the audited accounts (audit services).
Common Mistakes When Choosing a Transfer Pricing Documentation Firm
The errors that cost a Gurgaon company most are scope gaps agreed at engagement, not drafting slips: a report-only brief, a file that skips small or domestic transactions, and books that tell a different story from the study. The engagement letter fixes each one.
- Treating the report as a year end formality. The file must exist by the specified date, and the report is due a month before the return.
- Covering only large transactions. The report is needed for every international transaction, however small.
- Letting the books and the file diverge. Invoices and agreements in the file should match the accounting records.
- Missing the domestic threshold. Specified domestic transactions above ₹20 crore need the same discipline.
In practice, a Gurgaon subsidiary may recharge shared IT and management costs through journal entries while its intercompany agreement describes a different cost base. The study then benchmarks a markup the books do not show.
What happens after the Form No. 48 report is filed?
After filing, the records must stay ready for inspection. Under section 171(2) of the 2025 Act, the Assessing Officer or the Commissioner (Appeals) may, during any proceeding, require the company to furnish them within ten days of receiving a notice.
Section 171(3) allows that period to be extended, on application, by up to thirty further days.
The records are then kept for nine years under Rule 84(8). Before a fundraise or a sale, the transfer pricing history also feeds the tax due diligence in an M&A advisory process.
Discuss Your Transfer Pricing File
Gurgaon companies are served from the Delhi office in South Extension II. Share your details through the contact page, and the team will contact you about your file.
