Delhi NCR has quietly become one of India's biggest hubs for Global Capability Centres or GCCs. Walk through the business parks of Gurgaon, Noida and the wider National Capital Region and you will find hundreds of multinational companies running their finance, technology, analytics and customer support operations out of India. These centres are no longer just "back offices." They handle high-value, specialised work for their global parent companies. But with that growth comes a compliance responsibility that many GCCs underestimate transfer pricing and the rules governing it have just undergone their biggest overhaul in decades.
We work with GCC and shared services setups across Delhi NCR every day and the same question comes up in almost every conversation how do we make sure our intercompany pricing model is defensible if the tax department comes asking, especially now that the compliance framework itself has changed? This blog walks you through what transfer pricing really means for a GCC under the current law and why getting it right from day one saves a lot of pain later.
What's Changed The Income-tax Act, 2025
Every GCC in India provides services to its overseas parent or group companies. Since these are related-party transactions, Indian transfer pricing law requires that the pricing between them be at arm's length essentially, the same price that would apply between two unrelated companies dealing with each other. Until recently, this was governed by Sections 92 to 92F of the Income-tax Act, 1961. That framework has now been carried forward, restructured and renumbered into a single consolidated chapter under the Income-tax Act, 2025, which took effect from 1 April 2026.
The core principles behind transfer pricing India regulations remain unchanged the arm's length standard, the five recognised pricing methods and the basic documentation philosophy all continue as before. What has changed is the structure clearer, consolidated definitions of "associated enterprise" and "international transaction" and a new Block Transfer Pricing Assessment mechanism that allows an accepted arm's length price to apply to similar recurring transactions for the following two years, once prescribed conditions are met. For GCCs with steady, repetitive service arrangements year after year, this is a meaningful development worth building into your compliance planning.
For a business that's just set up its centre in Gurgaon or Noida, transfer pricing might feel like a background compliance task. In our experience, it's anything but and it's become even more important to get right as the new law beds in. Tax authorities scrutinise GCC transactions closely because the sums involved are large and the services are often specialised enough that comparability becomes a genuine point of dispute. This is exactly why choosing the right transfer pricing consultant in Delhi NCR early in your India journey and one who is current on the new regime, matters far more than most companies realise.
Building the Right Transfer Pricing Model for GCC and Shared Service Operations
The starting point for any GCC is deciding on the transfer pricing model for GCC and shared service operations. Most captive centres in India operate as low-risk service providers, earning a guaranteed cost-plus return rather than bearing entrepreneurial risk. But this label only holds up if the underlying facts support it and that principle hasn't changed under the new Act.
That's where a proper functional asset and risk analysis comes in. We look closely at what the Indian entity actually does does it perform routine, supervised functions or does it carry decision-making responsibility, own valuable intangibles or take on financial risk? The answers shape the entire transfer pricing position. Get the functional profile wrong and even a well-drafted cost-plus arrangement can unravel during an audit.
Intercompany Services, Cost Allocation and Benchmarking
Once the functional profile is clear, the next step is structuring intercompany services and cost allocation methods correctly. GCCs typically provide a mix of services IT support, finance and accounting, HR operations or research and each cost pool needs to be allocated logically to the entities that actually benefit from it.
From there, we move to cost plus markup and benchmarking analysis, which is really the heart of transfer pricing services in Gurgaon and across the region. The markup applied on costs has to be tested against comparable companies performing similar functions, using databases and search strategies that will hold up to scrutiny. All five arm's length methods carry forward unchanged under the new Act, so existing benchmarking approaches remain valid but a benchmarking study that cuts corners is still one of the most common reasons GCCs face TP adjustments later.
For technology-heavy or shared services centres in Noida, we often see additional complexity multiple service lines under one entity, each potentially needing separate benchmarking. Cost plus benchmarking for shared services in Noida is a specialised exercise and treating it as a one-size-fits-all calculation is a mistake we regularly help clients correct.
Documentation: Agreements, Invoicing and the New Form 48
Good transfer pricing isn't just about the numbers it's about the paper trail. Intercompany agreements and invoicing controls need to clearly reflect the services being rendered, the pricing methodology agreed upon and the terms under which payments flow. Weak or outdated agreements are a red flag for assessing officers, even when the underlying pricing is reasonable.
This documentation ultimately feeds into your Form 3CEB and transfer pricing documentation, which every Indian entity with international related-party transactions above the prescribed threshold must file. Under the Income-tax Rules, 2026 notified alongside the new Act, the familiar Form 3CEB is being replaced by a new Form No. 48, which carries additional disclosures, including around arm's length price determination for transactions covered under an Advance Pricing Agreement. Until this transition is fully bedded in, both references remain relevant and a Form 3CEB filing consultant in Gurgaon should already be tracking the changeover rather than working off the old format. Either way, the report should not just be numbers filled in at year-end it needs to be backed by a robust transfer pricing study, contemporaneous documentation and a benchmarking analysis that's been thought through not assembled in a hurry before the due date.
Year-End Monitoring and Margin Adjustments
Transfer pricing compliance doesn't end once the agreements are signed and the study is filed. Year end margin monitoring and adjustments are essential to make sure actual results stay within the arm's length range agreed upon. Currency fluctuations, unexpected cost increases or changes in service scope can all push actual margins outside the intended band. Catching this in real time, rather than after the financial year closes, gives a GCC far more flexibility to true-up pricing smoothly.
It's also worth checking whether your GCC's transaction values now fall within the recently widened Safe Harbour thresholds, which were expanded and made valid for two consecutive assessment years to give taxpayers more planning certainty. For GCCs providing routine, well-defined services within these limits, the Safe Harbour route can meaningfully reduce both scrutiny and documentation burden.
Managing Audit Risk and Disputes
Even with strong documentation, transfer pricing assessments in India can be intensive. Audit risk and dispute management is where experience really counts knowing how tax officers typically approach GCC cases, what comparables they tend to challenge, and how to build a defence file well before a notice arrives. We've represented several GCC clients through TP assessments and appellate proceedings, and the pattern is consistent: centres with strong, contemporaneous documentation face far shorter and less contentious audits. The new Block Transfer Pricing Assessment option adds further incentive to get the position right early, since a well-documented outcome accepted in one year can now extend protection into the following two years for similar recurring transactions.
Why Choose SKMC Global as Your Transfer Pricing Advisory Partner in Delhi NCR
There is much more to establishing and managing a GCC in India than just selecting office space and recruiting skilled personnel. Particularly with the recently reorganised law and rulebook in place, the transfer pricing framework you establish in the first year frequently dictates how well your compliance operates for years to come.
SKMC Global supports GCCs, foreign-owned companies and multinational groups in Delhi NCR with practical transfer pricing advisory designed around real business operations. Our team helps companies structure their transfer pricing model, conduct benchmarking studies, prepare documentation, draft intercompany agreements, manage Form 3CEB filings and support representation before tax authorities when required.
As a transfer pricing advisory firm in Delhi NCR, SKMC Global understands both the technical requirements of transfer pricing and the operational realities of GCCs in India. Whether your company is setting up a new GCC, expanding existing operations or reviewing its related-party pricing model, SKMC Global can help you build a compliant, defensible and audit-ready transfer pricing framework.