TRANSFER PRICING | ADVANCE RULINGS | APA | ARMS LENGTH DEFENCE
Transfer pricing disputes today are no longer limited to accounting or benchmarking issues. They involve complex questions of international taxation, business restructuring, valuation, treaty interpretation, cross-border financing, intellectual property ownership, profit attribution, and regulatory compliance. Legal Win Consulting LLP offers a multidisciplinary approach that combines legal, tax, regulatory, forensic, and litigation expertise to protect clients throughout the transfer pricing lifecycle.
ASSESSMENT & TPO REPRESENTATION
We represent clients at every stage of transfer pricing scrutiny.
Scope of Work:
- Replies to notices under Section 92CA
- Representation before TPO and Assessing Officer
- Handling of TP assessments and audit proceedings
- Compliance management (Form 3CEB, Master File, Local File)
ARM’S LENGTH PRICE (ALP) DEFENCE
We defend the commercial and economic rationale of pricing before tax authorities.
Our Defence Strategy Includes:
- Benchmarking analysis and comparables selection
- Rebuttal of TPO adjustments and re-characterisation
- Industry-based economic justification
- Defence against arbitrary margin re-computation
CORE PRACTICE AREAS:
TRANSFER PRICING ADVISORY & STRUCTURING
We design defensible, tax-efficient inter-company pricing frameworks for domestic and cross-border transactions.
Key Deliverables:
- End-to-end TP planning for multinational groups
- Structuring of related-party transactions
- Selection and justification of TP methods: CUP / RPM / CPM / TNMM / Profit Split
- Risk mapping for cross-border flows
DISPUTE RESOLUTION PANEL (DRP) STRATEGY
We provide high-impact litigation strategy before DRP under Section 144C.
Our Focus:
- Preventing crystallisation of tax demand
- Strategic objection drafting
- Technical + legal argument integration
- Pre-ITAT dispute resolution positioning
ITAT & HIGHER APPELLATE LITIGATION
We handle complex transfer pricing disputes before appellate authorities.
Capabilities:
- Appeals before Income Tax Appellate Tribunal (ITAT)
- Legal challenge to TPO methodology
- Expert-driven economic argumentation
- High Court writs in TP matters
ADVANCE PRICING AGREEMENTS (APA)
We help clients achieve long-term tax certainty and litigation avoidance through structured APA frameworks.
Services Include:
- APA application drafting and strategy
- Negotiation with CBDT APA authorities
- Bilateral / unilateral APA structuring
- Rollback provisions advisory
- Multi-year tax certainty planning
ADVANCE RULINGS & TAX STRUCTURING
We provide pre-transaction tax clarity solutions to eliminate future disputes.
Advisory Coverage:
- Cross-border structuring opinions
- Permanent Establishment (PE) risk assessment
- Withholding tax certainty planning
- Non-resident taxation clarity
- Transaction feasibility analysis
