Transfer pricing refers to the rules and methods for pricing transactions between enterprises under common
ownership or control. Because of the potential for cross-border controlled transactions to distort taxable
income, tax authorities in many countries can adjust intra group transfer prices that differ from what would
have been charged by unrelated enterprises dealing at arm’s length. A separate code on transfer pricing
under Sections 92 to 92F of the Indian Income Tax Act, 1961 (the Act) covers intro-group cross-border
transactions which is applicable from 1 April 2001 and specified domestic transactions which is applicable
from 1 April 2012.