Transfer pricing audit report

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CA Nayan Ratandhayara (Querist)

20 September 2012 Hi All,

Can any body share the transfer Pricing Audit report ?
As our is the new company & we are doing it first time. So it will be great help, if anyone share the report just for reference.

Main question is presentation of computation of arms lengths price.

Thank you in Anticipation

CA Yasaswy Sarma Veluri

CA Yasaswy Sarma Veluri (Expert)

20 September 2012 Dear Sir

Please send a test mail to cavysarma@gmail.com

will forward the report to you.

CA Nayan Ratandhayara

CA Nayan Ratandhayara (Querist)

24 September 2012 Mr. Srinath Sharma,

Awaiting your mail.

My Email Id is nayan.sr@gmail.com

Aashok Kumar Sharma online

Aashok Kumar Sharma

(Expert)

02 August 2025 I get that you’re looking for a **sample Transfer Pricing Audit Report** to use as a reference — especially to see how the **computation of Arm’s Length Price (ALP)** is presented.

Since actual audit reports contain confidential info, I can’t share real ones, but I can definitely help you with a **clear, structured sample outline and example** that you can adapt for your first TP audit report.

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## Sample Outline of a Transfer Pricing Audit Report (Form 3CEB + Computation)

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### 1. **Cover Page**

* Company name, PAN, FY
* Auditor’s name and membership number
* Declaration about TP compliance under Section 92E

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### 2. **Introduction**

* Brief about the company and related party transactions
* Summary of transactions covered under TP audit

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### 3. **Scope of Audit**

* Transactions examined (e.g., sale of goods to AE, services rendered, loans, etc.)
* Relevant provisions of Income Tax Act and TP Rules followed

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### 4. **Methodology**

* Explanation of ALP methods considered (CUP, Cost Plus, TNMM, etc.)
* Rationale for selecting the method used (e.g., Cost Plus method best fits due to nature of services)

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### 5. **Functional and Risk Analysis**

* Description of the functions performed, assets used, and risks assumed by parties

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### 6. **Selection of Comparables**

* Criteria for selecting comparable companies (industry, size, geography, financials)
* List of comparables selected with summary financials

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### 7. **Computation of ALP**

* Stepwise computation showing:

| Parameter | Value (₹) |
| --------------------------- | --------- |
| Cost of goods sold/services | XX,XX,XXX |
| Add: Markup percentage | X % |
| Computed ALP | XX,XX,XXX |
| Transaction price declared | XX,XX,XXX |
| Difference (if any) | XX,XXX |

* Explanation if adjustments made or range considered
* Charts/graphs showing comparables’ margins vs company’s margin

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### 8. **Conclusion**

* Statement on whether transactions are at arm’s length
* Confirmation of TP compliance

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### 9. **Annexures**

* List of associated enterprises
* Copies of agreements
* Extracts of financials of comparables
* Relevant legislation references

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## Quick Example: ALP Computation Table (for Cost Plus Method)

| Particulars | Amount (₹) |
| -------------------------- | ----------- |
| Cost of services rendered | 1,00,00,000 |
| Markup applied | 10% |
| ALP | 1,10,00,000 |
| Transaction value declared | 1,05,00,000 |
| Difference (Shortfall) | 5,00,000 |

**Comment:** The declared price is lower than ALP by ₹5 lakh, adjustments may be needed or justification provided.

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If you want, I can **help you draft a sample TP Audit report text** or a formatted template to get you started. Just say the word!

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