Bharat Transfer Pricing (Domestic and International Transactions) By CA Divakar Vijayasarathy & CA Sundara Rajan TK 8th Edition July 2026

 Transfer Pricing By Divakar Vijayasarathy 8th Edition 2026

Transfer Pricing By Divakar Vijayasarathy 8th Edition 2026

Description

Transfer Pricing, as an area of practice, has assumed enormous significance given the inherent ambiguous nature of the law and the scope for wide interpretations. The recent decisions by courts and the actions of the Revenue are an indicator of the direction in which this levy is poised. This book aims to simplify the provisions of international and domestic transfer pricing law in India. The book is viewed as an assessee’s and practitioner’s guide to transfer pricing to facilitate the interpretation and compliance of the legislation. Some of the highlighting features of this book are:-

• Simple and exhaustive coverage of the legal provisions as per the new Income Tax Act, 2025 Transfer pricing laws as amended by the Finance Act, 2026 have been covered
• UN Manual and OECD Guidelines have been referenced throughout for holistic understanding of the concepts.
• The conceptual and structural changes made in the provisions of the Income Tax Act, 2025 in comparison to the erstwhile Income Tax Act, 1961 have been analysed, and the ambiguities and practical issues have been highlighted.
• Two sample transfer pricing study reports have been provided to enhance the practical understanding of the documentation.
• Relevant case laws have been analysed and summarised to provide a ready reference for transfer pricing case laws
• Comparison of safe harbour margins with actual margins through benchmarking analysis
• The process of benchmarking with a recognised database has been explained by a simple step by step approach with screen shot depictions
• Completed Audit Report Format in Form 48 (erstwhile Form 3CEB)
• Practical check list for fulfilling Accountant’s responsibility while certifying Form 48
• Over 60 Practical issues faced by the assessee/tax advisors during the course of compliance and assessments have been elaborately discussed
• Supreme Court rulings have been extensively analysed

Content

Chapter 1       Relevance and Rationale of Transfer Pricing

Chapter 2       Transfer Pricing Law in India

Chapter 3       Methods for Determining the Arm’s Length Price

Chapter 4       Functions, Assets and Risk (FAR) Analysis

Chapter 5       Benchmarking and Selection of Comparables

Chapter 6       Transfer Pricing Adjustment

Chapter 7       Range Concept and Multi-Year Data

Chapter 8       Transfer Pricing for Loss-Making Companies

Chapter 9       Transfer Pricing for Specialised Capital Goods

Chapter 10     Transfer Pricing for Startups

Chapter 11     Limitation on Interest Deductions and Transfer Pricing for Financial Transactions

Chapter 12     Domestic Transfer Pricing

Chapter 13     Safe Harbour Guidelines with Comparison

Chapter 14     Practical Issues in Transfer Pricing

Chapter 15     Transfer Pricing Documentation

Chapter 16     Form 3CEB and Auditor’s Responsibility

Chapter 17     Master File and Country-by-Country Reporting in India

Chapter 18     Advance Pricing Agreements — An Indian Perspective

Chapter 19     Mutual Agreement Procedure

Chapter 20     Interplay of GAAR and Transfer Pricing

Chapter 21     Interplay of DTAA and Transfer Pricing

Chapter 22     Transfer Pricing — Global Perspective

Chapter 23     Transfer Pricing in UAE

Chapter 24     Supreme Court Decisions on Transfer Pricing Law

Chapter 25     UN & OECD Practical Manual on Transfer Pricing

Chapter 26     Sample Transfer Pricing Report — Case Study 1

Chapter 27     Sample Transfer Pricing Report — Case Study 2

Chapter 28     Statutory Provisions, Circulars and Notifications

Chapter 29     Glossary

About the Author

Divakar Vijayasarathy, founder and managing partner of DVS Advisors, is a chartered accountant by qualification with a strong passion towards domestic and international taxation law. An ex-banker with significant exposures in both domestic and international markets, founded the firm with a single- minded objective to provide value added cross border services to small and mid-size businesses having global aspirations.A passionate orator and professor on the subject of international and domestic taxation laws, he has presented numerous seminars and authored multiple books, most of which have been national publications. He has been part of several study groups and academic committees on the subject. A renowned expert on the subject of international tax, he was part of the expert team of ICAI for the certified course on International Taxation. He is a regular columnist and expert consultant for various national publications in India. He is a noted expert on the subject. He contributes regularly to national and international publications including being a Forbes Advisor. His thought leadership reflects a practical and strategic approach to taxation. He is the author of the publication “Don’t Just Pay Taxes”, released in association with Forbes Books, which articulates the core tax philosophy of DVS Advisors: “When business goals align with national priorities, taxes become profits.

Sundara Rajan leads the International Tax and Transactions practice at DVS. He is a Chartered Accountant with more than a decade of experience in International Tax, FEMA and Mergers. He is an active researcher in the space and regularly contributes to leading media houses on the subject. Sundara works closely with leading corporations in FMCG, Automobile, Textile, IT industry, etc and has been consistently recognised by his clients for his clarity of thought and ability to break down complex problems. Prior to this stint, Sundara was into credit underwriting and has underwritten over Rs. 5000 crores of SME retail book across Southern India for leading NBFCs.