Transfer pricing recordkeeping obligations require prescribed documents and attract penalties for non-maintenance or non-furnishing under law.

Maintenance of prescribed information and documents is mandatory for persons entering into international transactions and specified domestic transactions under Section 92D, with a Rule 10D threshold exemption and a Master File requirement for constituent entities. Records must be retained for eight years. Failure to maintain records attracts penalty under Section 271AA equal to two percent of the value of each specified domestic transaction. Furnishing of prescribed information on notice is required within the statutory period (thirty ten days as amended), extendable on application, and failure to furnish attracts penalty under Section 271G equal to two percent of the transaction value. Section 92E requires CA report in Form 3CEB.

---

---

---