Transfer Pricing Audit & Litigation Support

Our in-house lawyers and senior Chartered Accountants represent clients at every stage of a transfer pricing dispute — from the first TPO notice to the final ITAT order.

Overview

Litigation-tested representation, not just documentation review

A transfer pricing dispute can move through multiple forums — the Transfer Pricing Officer, the Dispute Resolution Panel, the Commissioner of Income Tax (Appeals), and the Income Tax Appellate Tribunal. Each requires a distinct strategy, and consistency across all of them.

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Who this applies to

Any company facing a TP adjustment, audit notice, or appellate proceeding, at any stage of the dispute lifecycle.

What We Cover

Every stage of a TP dispute

TPO Assessment

Representation and submissions during reference under Section 92CA.

DRP Objections

Filing and arguing objections before the Dispute Resolution Panel.

CIT(A) & ITAT

Appellate representation with detailed factual and legal briefs.

Secondary Adjustments

Advisory on Section 92CE secondary adjustment and repatriation implications.

Our Process

A consistent position from notice to order

Step 1

Case Assessment

Review the TPO's order or notice and identify the core dispute points.

Step 2

Response Strategy

Build a factual and legal response grounded in your original documentation.

Step 3

Representation

Appear and argue before the relevant forum — TPO, DRP, CIT(A) or ITAT.

Step 4

Resolution & Follow-Through

Pursue further appeal or MAP where necessary, and implement any adjustment.

Why Work With Us

Lawyers on staff, not outsourced when disputes arise

In-House Legal Team

Three dedicated lawyers focused exclusively on TP and international tax disputes.

Continuity of Strategy

The same team from documentation through to final appeal.

Multi-Forum Experience

Track record before the TPO, DRP, CIT(A) and ITAT.

FAQs

Common questions

What is the Dispute Resolution Panel (DRP)? +

The DRP is a collegium of senior tax officers that reviews objections to a draft assessment order before it is finalised, offering a faster alternative to a first appeal.

What is a secondary adjustment under Section 92CE? +

Where a primary TP adjustment is accepted or upheld, Section 92CE can deem the resulting excess money to be an advance requiring repatriation, or subject to notional interest if not repatriated within the prescribed time.

Facing a TP audit or appeal?

Talk to our litigation team today.