Bharat’s Law & Practice of Transfer Pricing (Domestic & International Transactions) by CA. Divakar Vijayasarathy – 8th Edition 2026.

Transfer Pricing remains the most aggressively litigated domain in international taxation, requiring precise documentation and unassailable benchmarking. Law & Practice of Transfer Pricing, published by Bharat Law House, provides a 360-degree view of both domestic and cross-border intra-group transactions. Currently in its 8th Edition (2026), this comprehensive treatise bridges the gap between statutory theory and practical compliance, making it an indispensable asset for multinational enterprises (MNEs) and their auditors.

Mastering the Arm’s Length Principle

The book breaks down the complex mechanics of determining the Arm’s Length Price (ALP) through a structured, 29-chapter approach:

• FAR Analysis & Benchmarking: Step-by-step guidance on conducting robust Functions, Assets, and Risk analyses, applying the Range Concept, and utilizing multi-year data for selecting comparables.

• Specialized Scenarios: Dedicated chapters on navigating transfer pricing for Loss-Making Companies, Startups, Specialized Capital Goods, and Financial Transactions (including limitations on interest deductions).

• Compliance & Audit Defenses: A deep dive into Transfer Pricing Documentation requirements, the auditor’s strict responsibilities under Form 3CEB, and maintaining Master Files and Country-by-Country (CbC) Reporting in India.

Dispute Resolution & Global Perspectives

Transfer pricing disputes are inevitable, and this book arms you with the tools to resolve them efficiently without lengthy litigation:

• Advance Pricing Agreements (APA) & MAP: Detailed Indian perspectives on securing APAs and navigating the Mutual Agreement Procedure to prevent double taxation.

• Interplay with GAAR & DTAA: Critical analysis of how the General Anti-Avoidance Rules (GAAR) and Double Taxation Avoidance Agreements (DTAA) intersect with transfer pricing adjustments.

• International Frameworks: Explores the global perspective, including the latest UN & OECD guidelines, UAE Transfer Pricing regulations, and landmark Supreme Court decisions shaping the law.

Who Should Buy This Book?

• Chartered Accountants & Transfer Pricing Specialists: The ultimate desk reference for drafting TP studies, benchmarking reports, and filing Form 3CEB.

• Corporate Tax Heads & CFOs: Essential for multinational corporations and large domestic groups needing to structure inter-company pricing policies safely.

• Revenue Officers & Appellate Litigators: Provides the heavily researched, authoritative precedent required for arguing or defending complex TP adjustments at the ITAT and High Courts.

About the Authors

CA. Divakar Vijayasarathy & CA. Sundara Rajan TK

CA. Divakar Vijayasarathy and CA. Sundara Rajan TK are prominent Indian Chartered Accountants, corporate tax strategists, and the core leadership behind the DVS Advisory Group (DVS Advisors LLP), a global international tax strategy and private equity firm based in Chennai.

CA. Divakar Vijayasarathy, the Founder and CEO of DVS, is a World Economic Forum New Champion and a Forbes-featured author who has written over 15 authoritative books on domestic and international tax laws. He is the creator of the globally recognized Tax As Profit™ Framework.

CA. Sundara Rajan TK, Chairman and Managing Partner at DVS, leads the firm’s tax structuring and litigation operations. He specializes in complex corporate tax, FEMA regulations, and cross-border M&A transactions, bringing unparalleled practical insight into this masterwork.

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