In India, transfer pricing regulations are governed by Sections 92 to 92F of the Income Tax Act, 1961 and the Income Tax Rules. These require taxpayers to maintain prescribed documentation and ensure that international transactions and specified domestic transactions are carried out at arm’s length prices. The rules prescribe methods for determining arm’s length prices and provide for Transfer Pricing Officers to compute adjustments in case of deviations. Finance Act 2025 has extended transfer pricing provisions to business restructurings and permanent establishments.
