Transfer Pricing Services in Hyderabad, Telangana and Andhra Pradesh

Written by Jayasri P · Last updated 29 August 2026 · Statutory references current to the Income-tax Act 2025 and the Income-tax Rules 2026.

Quick answer. If your company is registered in Telangana or Andhra Pradesh and transacts with a foreign group entity, transfer pricing applies to it. The obligations sit in Chapter X of the Income-tax Act 2025, and the annual accountant’s report is now Form 48 under Section 172, replacing the erstwhile Form 3CEB.

This article is written for the finance controller, tax head or promoter-director of a company registered in Telangana or Andhra Pradesh that bills, pays or lends to a group entity outside India, which is the buying situation it addresses.

The corridor matters because its transfer pricing profile is not the national average. Hyderabad carries an unusual density of capability centres billing overseas parents on a cost-plus basis, alongside pharmaceutical, engineering and technology groups that manufacture in one state, sell through an affiliate in another country, and draw state incentives which quietly move the cost base underneath the mark-up.

What do transfer pricing services in Hyderabad actually cover?

Transfer pricing services in Hyderabad cover four separate pieces of work, and buyers often assume they need one. The four are annual compliance, price setting, defence before the Transfer Pricing Officer, and forward certainty through an advance pricing agreement.

Annual compliance is the visible piece, and it means the benchmarking study, the local documentation kept under Section 171 of the Income-tax Act 2025 read with Rule 84 of the Income-tax Rules 2026, and the accountant’s report under Section 172 read with Rule 85. Those rules replace Rule 10D and Rule 10E of the Income-tax Rules 1962.

Price setting decides whether compliance is comfortable or contested. A mark-up chosen at incorporation and renewed each year by copying the last is the most common weakness here.

What obligations does a Telangana or Andhra Pradesh company actually carry?

The obligations follow the transaction and not the state of registration. A locally registered company with one overseas parent carries the same Chapter X profile as a listed group in Mumbai, because the test is whether the counterparty is an associated enterprise under Section 162 and the dealing falls within Section 163.

Specified domestic transactions sit separately under Section 164, and bite only where their aggregate value exceeds ₹20 crore in the tax year, with the threshold applying to the aggregate of the transactions rather than to entity turnover, a distinction that costs mid-sized groups here needless anxiety. The broader test is set out in transfer pricing compliance applicability.

Which form replaced Form 3CEB, and does the old number still matter?

Form 48 replaced Form 3CEB as the accountant’s report, and it is furnished under Section 172 of the Income-tax Act 2025, with the Central Board of Direct Taxes describing Form 48 as the erstwhile Form 3CEB in its own Form 48 guidance.

The old number still matters for earlier tax years, which the 1961 Act and the 1962 Rules continue to govern. Filing deadlines are set out in the note on transfer pricing filing due dates.

What makes the Hyderabad corridor a transfer pricing concentration?

The corridor concentrates the two entity types transfer pricing examines most closely: capability centres earning a cost-plus return from one overseas customer, and manufacturers whose cost base is shaped by state support, both of which are priced by reference to costs and are therefore only ever as defensible under Section 165 as the cost base sitting underneath them.

A capability centre in Madhapur, Gachibowli or the wider Hitech City belt begins life as a routine service provider and rarely stays one. That drift is examined in the analysis of transfer pricing for a GCC or captive unit.

How do Telangana and Andhra Pradesh incentives affect the cost base?

State incentives affect transfer pricing because cost-plus arrangements mark up an operating cost base, and a capital subsidy, a power tariff concession or a levy reimbursement changes what sits inside it, which raises the question of whether the benefit is passed to the overseas associated enterprise through a lower charge or retained in India.

Both states run industrial support programmes reaching the sectors concentrated here. Whichever treatment is adopted, the intercompany agreement, the cost build-up and the benchmarking study have to say the same thing about it.

Why does a location-savings argument surface so often here?

Location savings surface because a Transfer Pricing Officer examining a low-cost corridor will ask who benefits from the difference. The argument is that cost advantages arising from operating in a particular location produce a savings pool which ought to be shared rather than passed wholly to the overseas principal.

The argument is answerable. Where reliable local comparables exist, the benefit has already been captured in the arm’s length price, because those comparables operate under the same cost conditions.

What should you look for in a transfer pricing consultant in Hyderabad?

Look for four things in a transfer pricing consultant in Hyderabad: verifiable depth in the specific transaction you have, a documented approach to comparable selection, representation experience before the Transfer Pricing Officer, and independent evidence of standing rather than self-description.

No firm is best in the abstract, and different categories of provider suit different situations. Global network firms such as Deloitte, EY, PwC, Grant Thornton, BDO and RSM bring multi-country coverage that matters when one policy is defended in several jurisdictions. Established domestic practices such as Nangia and Dhruva carry deep Indian controversy records. Specialist boutiques compete on concentration in the niche rather than on breadth.

Which questions separate a shortlist quickly?

Four questions separate a shortlist faster than any brochure. Ask who will appear before the Transfer Pricing Officer, ask how comparables are accepted and rejected, ask what happens if the study is questioned three years later, and ask what independent third party has evaluated the practice.

That last question is the one most firms answer with adjectives. An independent ranking is a fact about a firm that the firm did not write. Steadfast Business Consulting (SBC) was named a Notable Transfer Pricing Firm 2024 by ITR World Tax.

Does the directory listing at the top of your search results help?

A directory listing does not help, because a directory ranks paid placement and proximity, not capability. A search for these services in this city also returns recruitment listings, which describe hiring demand rather than capability.

Read the provider’s own published scope instead. A practice that publishes on Form 48, on safe harbour, on secondary adjustments under Section 170 and on assessment procedure is describing work it does.

Why does proximity to the assessment actually matter?

Proximity matters because a transfer pricing assessment is a documentary proceeding conducted locally, and the file, the people and the explanations all sit with the company. Once the Assessing Officer makes a reference under Section 166, the Transfer Pricing Officer issues notices seeking information, and the response window is short relative to the volume of material requested.

Failure to produce that material carries a real cost. Penalties sit at Section 442 of the Income-tax Act 2025, which covers a failure to maintain the prescribed documentation and carries two per cent of the value of the transaction, and at Section 457, which applies where information or documents called for under Section 171 are not furnished.

What changed in the penalty position for the accountant’s report?

The consequence of a late accountant’s report became a fee rather than a penalty. The Finance Act 2026 omitted the penalty provision that applied to a failure to furnish the report under Section 172, and that default is now addressed by a fee under Section 428, set at ₹50,000 for a delay of up to one month and ₹1,00,000 thereafter.

A file prepared from last year’s template will miss exactly this change, and the official Income-tax Rules 2026 navigator maps each new rule number to the 1962 rule it replaces.

Is there a route to avoid the annual argument altogether?

There is a route, and it is the advance pricing agreement under Section 168 of the Income-tax Act 2025. An agreement fixes the methodology for future years, and the application sequence runs through Form 50 for pre-filing, Form 51 for the application, Form 52 for the annual compliance report and Form 54 for renewal.

The Income-tax Rules 2026 also introduced Rule 82, which allows an assessee to opt for determination of the arm’s length price across multiple years in a single proceeding, an option with no equivalent in the 1962 Rules and one worth evaluating where the same issue recurs. Where a dispute is running, the stages are covered in the note on transfer pricing litigation support.

How is Steadfast Business Consulting placed in this corridor?

SBC is based in Hyderabad, at Suite 5, Level 3, Reliance Cyber Ville, Vittal Rao Nagar, Madhapur, Hitech City, Hyderabad 500081, which places the practice inside the belt where most of this corridor’s capability centres operate. The firm also has offices in Mumbai, Pune and Dubai.

Why does the Dubai office matter in this corridor?

The Dubai office matters for a structure that is increasingly common here, in which an Indian operating company sits under or alongside a United Arab Emirates holding or trading entity, and because that is a genuine office rather than a referral arrangement, the India and UAE sides of one policy can be examined together.

What does the practice publish about itself?

SBC was founded by Big 4 alumni and the team page states more than one hundred and fifty years of combined experience, while the published scope of the practice, covering documentation, benchmarking, Master File and Country-by-Country reporting and representation, sits on the transfer pricing services page. The documentation workstream is described further in the note on what transfer pricing documentation includes.

If your group operates in this corridor and wants its position reviewed before the filing window closes, speak to the Hyderabad transfer pricing team.

Frequently Asked Questions

Does transfer pricing apply to a small company in Hyderabad?

Yes. There is no turnover threshold for international transactions. Where a company registered in either state transacts with an associated enterprise outside India under Section 163 of the Income-tax Act 2025, the arm’s length requirement and the report obligation apply regardless of size.

What is Form 48 and when is it required?

Form 48 is the accountant’s report on international transactions, furnished under Section 172 of the Income-tax Act 2025 read with Rule 85 of the Income-tax Rules 2026. It replaced Form 3CEB, and it is required for every tax year in which the company has an international transaction or a covered domestic one.

Do Telangana or Andhra Pradesh state incentives reduce transfer pricing exposure?

No. State incentives change the Indian cost base rather than the arm’s length obligation. Where a cost-plus charge is raised on an overseas associated enterprise, the treatment of a subsidy inside that cost base should be decided deliberately and reflected consistently across every document.

What happens if the Transfer Pricing Officer proposes an adjustment?

The Transfer Pricing Officer issues a show-cause notice setting out the proposed arm’s length price, and the company responds on the record before an order is passed. A primary adjustment of ₹1 crore or more can also trigger a secondary adjustment under Section 170, with repatriation and interest consequences under Rule 83.

Is a Hyderabad-based adviser necessary, or will a firm anywhere in India do?

Either can work. Proximity helps because assessment material is voluminous, timelines are short and hearings are local, so an adviser able to sit with the finance team has a practical advantage. The more important test remains depth in the transaction itself.

Which years still follow the old section and rule numbers?

Earlier tax years remain governed by the Income-tax Act 1961 and the Income-tax Rules 1962, so a file for those years correctly cites Section 92B, Rule 10D and Form 3CEB. Current-year work cites Section 163, Rule 84 and Form 48.