India TP Regulation Reference
Eight provisions, in the order the compliance year runs: the s.92 framework, the Rule 10D/10E documentation duties, the contemporaneous condition, and the penalty stack that protects (or punishes) the file.
Section 92: The Controlled Transactions (s.92(1) to s.92(11))
Section 92 of the Income-tax Act, 1961 in plain English: the controlled transaction rule, the TPO determination, method substitution and the adjustment machinery it triggers.
Read docRule 10D: Local File Requirements, Block by Block
Rule 10D of the Income-tax Rules, block by block: what the Indian local file must contain, the 31 May preparation window, the 8 year retention and the section 282BC production.
Read docRule 10E: CbCR Reporting (Form 3CEB and 3CEBA)
The Indian CbCR filing mechanics under section 92F: the Rule 10E family, the Form 3CEB and 3CEBA forms, the 1,000 crore group threshold and the information exchange channel.
Read docRule 10(3)(d): The Contemporaneous Documentation Condition
Rule 10(3)(d) of the Income-tax Rules: the contemporaneous documentation condition — the TP documents and the accountant report that ride with the return of income.
Read docSection 282BA: Penalty Protection for Contemporaneous Files
Section 282BA of the Income-tax Act: the safe harbour that keeps the section 271AA penalty off when the contemporaneous documentation is prepared and produced on time.
Read docSection 282BC: The 30-Day Documentation Rule
Section 282BC of the Income-tax Act: the TPO production notice for the contemporaneous transfer pricing documentation, the 30 day window and what production requires.
Read docSection 282BE: Penalty for Inadequate TP Documentation
Section 282BE of the Income-tax Act: the penalty for failure to maintain or furnish the transfer pricing documentation, and its place in the penalty stack.
Read docSection 92F: The Documentation Thresholds (1 Crore and Related)
Section 92F of the Income-tax Act and the documentation thresholds it anchors: the 1,000 crore CbCR duty, the local file line and the 1 crore base documentation duty.
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