Individual CA to Full-Service Advisory Firm: Overseas Parent Expectation

An individual Chartered Accountant works well for a domestic startup in its first year. The company files GST returns, closes the books each quarter, submits an income tax return, and that is largely the compliance surface. Add a foreign parent, and the surface changes immediately. FEMA reporting, transfer pricing documentation, related-party contracts, secretarial filings tied to share allotments, and now employment or IP contracts that the accounts do not even touch. The CA who handled your early years may be excellent at what they do. The question is whether what they do still covers what your company now needs.

When does a foreign-owned Indian subsidiary actually need a full-service advisory team?

A foreign-owned Indian subsidiary needs a full-service CA, CS, and legal advisory team once it has a headcount above five, is receiving intercompany charges from the parent, has completed one share allotment, is executing contracts with Indian customers or vendors, or has a seconded employee from the parent working in India. Any single one of these events creates obligations across tax, secretarial, and legal simultaneously. An individual CA cannot sign company secretarial filings, cannot draft contracts, and is typically not structured to flag PE exposure or maintain transfer pricing documentation. The firm you need is not bigger; it is broader.

Why the compliance surface is different when your parent is overseas

An Indian subsidiary of a foreign company is, in the words of the Companies Act, 2013, an Indian company with a foreign promoter. From India’s regulatory standpoint, it is fully subject to domestic law: it files under the Income Tax Act, 2025 (which replaced the Income Tax Act, 1961 from FY 2026-27 onwards), it registers and returns under the Goods and Services Tax (GST) framework, it files annual returns with the Ministry of Corporate Affairs (MCA), and it maintains statutory registers like any private limited company. None of that changes because the parent is in the US, Singapore, the UK, or anywhere else.

What changes is the additional compliance layer that sits on top. Every rupee received from the parent as share capital triggers a Form FC-GPR filing with the Reserve Bank of India (RBI) within 30 days of share allotment, under the Foreign Exchange Management Act (FEMA) 1999 and the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019. Every service rendered by the subsidiary to the parent, every fee paid to the parent for technology or management, and every interest payment on an intercompany loan is subject to transfer pricing rules under Section 161 of the Income Tax Act, 2025 (corresponding to Section 92 of the repealed Income Tax Act, 1961), and must be priced at arm’s length and documented annually in a Form 3CEB report certified by a practising CA. The Annual Performance Report (APR) must be filed with the RBI each year. The Foreign Liabilities and Assets (FLA) return must be filed annually by 15 July under FEMA.

A note on Act references: the Income Tax Act, 1961 was replaced by the Income Tax Act, 2025 (ITA 2025) effective FY 2026-27. Section numbers have been renumbered throughout. Wherever this article cites ITA 1961 section numbers, the bracketed ITA 2025 equivalent is provided. The underlying transfer pricing principles are substantively unchanged; only the numbering differs.

Each of these obligations has a hard deadline and its own form. An individual CA often handles the income tax filings. Whether they also track FEMA deadlines, hold a company secretarial practising certificate, and can draft or review the intercompany service agreement is a different question.

Seven signals your Indian subsidiary has outgrown an individual CA

The threshold is not a revenue number. It is a function of complexity. These seven events, individually or together, mark the point where the individual CA model starts producing gaps.

Signal 1: The parent has charged a management fee, royalty, or technology fee

Once the parent charges the Indian subsidiary for services rendered, a transfer pricing obligation is live. This is not an optional documentation exercise. Section 171 of the Income Tax Act, 2025 (formerly Section 92D of the Income Tax Act, 1961) requires every person who has entered into an international transaction to maintain prescribed documentation. If the subsidiary’s aggregate international transactions exceed ₹1 crore, a Form 3CEB must be filed by a practising CA who is specifically structured to provide transfer pricing certification. The arm’s length price used in the transaction must be supported by a contemporaneous transfer pricing study. An individual CA who handles tax returns can sign the Form 3CEB, but producing the economic analysis behind the study typically requires a firm with dedicated transfer pricing capacity.

Signal 2: A share allotment has happened and an FC-GPR was filed

The FC-GPR deadline is 30 days from the date of share allotment, not from the date of funds receipt. Many subsidiaries miss this distinction. If the filing is late, the contravention falls under FEMA and must be compounded with the RBI. The compounding fee is linked to the amount of the transaction and the delay period. Importantly, the AD bank (Authorised Dealer bank) will ask for a practising CA certificate alongside the FC-GPR submission. If the subsequent FLA return picks up a discrepancy between the reported capital infusion and the FC-GPR data, a further FEMA query follows. Managing this chain requires someone who tracks FEMA as a discrete workstream, not as an add-on to income tax filing.

Signal 3: A CS-specific event has occurred without a CS

Company Secretarial events are not optional. Board meetings must be held and minutes recorded. If the subsidiary has issued fresh shares, the allotment must be reflected in the register of members and in e-Form PAS-3. A change in directors requires e-Form DIR-12. Any change in the registered office requires e-Form INC-22. These are MCA filings that must be made by a practising Company Secretary (CS) or under the supervision of one. If the individual CA is not also a CS with a valid certificate of practice, these filings are either delayed or handled by a third-party CS the founder is managing directly. Either arrangement creates a coordination gap.

Signal 4: The subsidiary is hiring employees and has executed or is negotiating employment contracts

Employment contracts in India are not generic templates. The applicable labour laws (the Industrial Disputes Act, 1947, the Code on Wages, 2019, and state-specific shops and establishments acts) govern termination, notice periods, gratuity eligibility, and the mandatory content of offer letters and employment agreements. If the subsidiary is hiring senior employees with non-compete or IP assignment clauses, those clauses have to hold up under Indian contract law. A CA practice does not draft contracts. A general individual CA does not advise on whether a non-solicitation clause is enforceable in Maharashtra. These are legal workstream items.

Signal 5: The parent is asking for management accounts or a financial close in a format your CA cannot produce

Foreign parents typically expect monthly or quarterly management accounts, often in their own reporting currency, mapped to their group chart of accounts (which may be IFRS or US GAAP aligned), and reconciled to the Indian statutory accounts maintained under Ind AS or the Accounting Standards notified for SMCs. The reconciliation between Indian statutory accounts and group reporting is not complex in concept but requires familiarity with the parent’s expectations. An individual CA running ten or fifteen clients in parallel does not typically have the bandwidth to handle this on a tight monthly deadline while also managing the subsidiary’s statutory compliance. This is the gap where a VCFO (Virtual CFO) function within a full-service firm adds immediate value.

Signal 6: A due diligence request has arrived from the parent, a co-investor, or a prospective customer

Due diligence requests expose every historical gap at once. Whether it is a commercial customer running a vendor qualification, an investor running a company-level check before committing capital to the parent, or the parent itself doing a periodic audit of its India entity, the data room will be asked for: tax filings and demand orders, FEMA compliance records, statutory registers, board minutes, employment contracts, IP assignment agreements, and transfer pricing documentation. If these are scattered across an individual CA’s records, a third-party CS, and a folder on the founder’s laptop, the assembly process is slow and the gaps become visible.

Signal 7: The parent has seconded an employee to the Indian subsidiary

A secondment, where the parent company sends an employee to work in India under the operational control of the Indian subsidiary, creates a compliance chain that spans three disciplines simultaneously. On the payroll and employment side, the seconded employee typically needs a shadow payroll in India, and the subsidiary must manage TDS on salary under the Income Tax Act, 2025. On the corporate tax side, if the seconded employee is senior enough and exercises decision-making authority in India, the parent company may have created a Permanent Establishment (PE) in India, exposing the parent to Indian corporate tax on the profits attributable to that PE. On the FEMA side, the salary recharge from the subsidiary back to the parent for the cost of the seconded employee is a cross-border remittance requiring Form 145 and Form 146 under the ITA 2025. An individual CA who does not work across these three disciplines will see the payroll deduction. They are unlikely to flag the PE risk or prepare the Forms 145 and 146 before the recharge payment leaves India.

Treelife’s secretarial compliance practice works with Indian subsidiaries of foreign companies on FEMA filings, event-based MCA compliance, and annual statutory maintenance.

What falls through the gap between an individual CA, a third-party CS, and no legal cover

The specific failure mode of the fragmented individual CA model is not that any one adviser is incompetent. It is that the obligations that require two or three disciplines to act in coordination end up in no one’s queue.

The clearest example is a capital infusion from the parent. The sequence runs: parent wires capital, Indian bank receives funds and issues a Foreign Inward Remittance Certificate (FIRC), shares are allotted, FC-GPR is filed within 30 days, share certificates are issued, the register of members is updated, and the new shareholding is reflected in the next annual return. For this sequence to work without a contravention, the CA handling the FC-GPR needs to coordinate with the CS updating the register and issuing the share certificates. If they are different people who do not communicate with each other, the FC-GPR may be filed with allotment date and consideration figures that do not match the register, which creates a discrepancy the RBI will eventually surface.

Similarly, when the parent wants to charge the Indian subsidiary a technology access fee, the intercompany agreement needs to be drafted (legal), priced at arm’s length (transfer pricing), and reflected in the tax filings with a Form 3CEB (CA). If the CA, the legal adviser, and the founder are each working from their own version of the arrangement, the documentation will not be consistent, and a transfer pricing adjustment will follow.

Table 1: Compliance obligations of a foreign-owned Indian subsidiary and the discipline required

Obligation	Deadline	Responsible discipline
Form FC-GPR (share allotment to foreign parent)	Within 30 days of allotment	CA (FEMA-aware)
FLA return (foreign liabilities and assets)	15 July each year	CA (FEMA-aware)
Form 3CEB (transfer pricing certification)	31 October each year (extended dates apply)	CA (transfer pricing certified)
Annual return (MGT-7A)	Within 60 days of AGM	CS
Financial statements filing (AOC-4)	Within 30 days of AGM	CS + CA
Board meeting minutes and statutory registers	Ongoing	CS
Employment contract drafting and review	On hiring	Legal
Intercompany service agreement	Before charging begins	Legal + CA
Transfer pricing study (domestic report)	Annual, before 3CEB date	Transfer pricing specialist
GST returns (GSTR-1 / GSTR-3B / GSTR-9)	Monthly / quarterly / annual	CA

How transfer pricing obligations escalate and why timing matters

Transfer pricing is the area where the cost of the individual CA model is most quantifiable. The Income Tax Act, 2025 defines an “international transaction” at Section 163 (formerly Section 92B of the repealed Income Tax Act, 1961) to include services, finance, cost sharing, and the use of intangibles. The arm’s length standard under Section 165 (formerly Section 92C) requires the subsidiary to apply one of six specified methods (comparable uncontrolled price, resale price, cost plus, transactional net margin, profit split, or other method) and to maintain documentation prescribed under Rule 10D of the Income Tax Rules, 1962.

The documentation must be contemporaneous. This means the study and the supporting comparable analysis must exist before the transaction is reported in the return of income, not assembled after a notice arrives. If a transfer pricing officer issues a notice under Section 166 (formerly Section 92CA) and the subsidiary cannot produce a study, the officer will make an adjustment of their own. Adjustments commonly run to multiples of the original transaction value, with interest and potentially a penalty of up to 2% of the value of the international transaction for failure to maintain or furnish documentation under the ITA 2025 penalty provisions.

An individual CA filing the tax return can include the Form 3CEB. But the economic analysis behind the certificate, the comparable set, and the tested party selection are specialist work. Firms that run this as a standalone deliverable, separated from the rest of the compliance stack, have historically produced studies that do not survive a rigorous transfer pricing audit because the transfer pricing consultant did not have visibility into the actual intercompany contracts. A full-service firm connects the legal drafting, the pricing decision, and the documentation, producing a study that is consistent with the contracts and the books.

The cost of switching: what a full-service firm actually costs at different scales

The honest answer is that a full-service firm costs more than an individual CA. The relevant comparison is not the fee line but the all-in risk-adjusted cost.

Table 2: Indicative cost comparison for Indian subsidiary advisory at two revenue scales

Scale	Individual CA arrangement	Full-service firm (CA + CS + legal)
Revenue below ₹1 crore, no intercompany charges	₹1.5 to 3 lakh per year (tax + basic filings)	₹4 to 7 lakh per year
Revenue ₹1 to 10 crore, intercompany charges, 5 to 15 employees	₹3 to 5 lakh (CA) + ₹1 to 2 lakh (third-party CS) + ad hoc legal	₹8 to 15 lakh per year (integrated)
Revenue above ₹10 crore, transfer pricing requirement, formal HR	₹5 to 8 lakh (CA + TP study) + ₹2 to 3 lakh (CS) + legal retainer	₹15 to 30 lakh per year (VCFO + legal + secretarial)

The fee gap narrows significantly at the second and third rows when you count all the fees being paid separately. What the fee comparison does not capture is the penalty exposure that accumulates when coordination breaks down. A missed FLA return attracts a Late Submission Fee (LSF) under FEMA calculated at 0.025% per day of the relevant liability, subject to a minimum of ₹10,000. A transfer pricing addition of ₹50 lakh with a 2% documentation penalty and interest under Section 234B adds up to a number that dwarfs the difference between the two advisory models for years.

What the transition from an individual CA to a full-service firm looks like

The transition is not a hard cutover. The most efficient approach is a phased handover over one to two months, timed around a natural calendar break such as the start of a financial year or immediately after the annual return has been filed.

The handover sequence typically runs as follows:

1. The new firm conducts a compliance health check against the subsidiary’s existing records: FEMA filings, MCA annual returns, GST returns, transfer pricing documentation if any, and employment contracts. This maps the gaps before responsibility transfers.
2. Outstanding compliance is cleaned up by the existing CA before handover or by the new firm in the first engagement month, with a clear allocation of responsibility.
3. Statutory registers are transferred to the new CS. The new CS files any updating forms required to reflect current director and shareholding details.
4. The intercompany agreements are reviewed by the legal team and updated if the pricing or structure has changed.
5. The transfer pricing study for the current financial year is commissioned, using the contracts and transaction data now held by a single team.
6. The parent’s reporting requirements are mapped: monthly management account format, currency, accounting policy alignment, and group deadline.

The existing CA should be engaged transparently in the handover. Most individual CAs are cooperative and prefer an organised exit over an acrimonious one. The main risk is that the CA holds data in their own systems rather than in the subsidiary’s name. Bank portal logins, GST portal access, and income tax login should all be transferred to the company’s own email credentials before the handover is complete.

What to look for in a firm when your parent is overseas

The parent being overseas adds a specific requirement beyond the standard compliance scope. The India team needs to be able to communicate with a finance function operating in a different time zone, in a different accounting format, and with a different understanding of how Indian regulatory requirements work.

Practically, this means the firm should be able to:

• Produce management accounts reconciled to the parent’s reporting currency and chart of accounts, on the parent’s close deadline (which may be the calendar year, not the Indian FY)
• Handle DTAA (Double Taxation Avoidance Agreement) analysis when the parent charges royalties or technical fees, to determine the withholding tax rate applicable under the relevant treaty
• Coordinate with the parent’s global legal or finance team on intercompany agreements without requiring the founder or country head to act as the relay
• File Form 145 and Form 146 (replacing Form 15CA and Form 15CB respectively under the Income Tax Act, 2025) for every cross-border payment to the parent, covering the remittance nature, DTAA applicability, and applicable TDS rate, before the payment leaves India. AD banks will not process the transfer without these forms. Finance teams still using Form 15CA/15CB workflows after 01/04/2026 are filing with superseded forms.
• Flag FDI sectoral cap issues if the subsidiary plans to invest downstream in another Indian company, because a foreign-owned company making downstream investments is classified as an FOCC (Foreign-Owned or Controlled Company) and the investment is treated as indirect FDI under the consolidated FDI Policy

Common mistakes that cost subsidiaries time and money during this transition

Waiting for a regulatory notice before switching

The most common mistake is using a regulatory notice as the decision trigger rather than the compliance calendar. By the time an RBI query arrives on a late FLA return or a transfer pricing notice is received for a documentation gap, the original omission may be two or three years old. Compounding interest and penalties run from the date of the original due date, not from the date of the notice. Proactive transition before the compliance gaps deepen is always less expensive than reactive remediation.

Assuming the individual CA can add CS and legal services

Some individual CAs position themselves as full-service by referring CS and legal work to third parties they coordinate. This is not equivalent to an integrated firm. The referral model reproduces the coordination gap under a single invoice. The CA is still managing two external vendors, and the information shared across those three parties is incomplete by the time any one filing is made.

Transitioning at the start of a high-activity period

Moving advisers in October, during the transfer pricing filing season, or in March, during the financial year close, is unnecessarily risky. The new firm is receiving incomplete information while the former CA is trying to hand over files. Time the transition for May or June, after the annual return filing and before the FLA return deadline, so the new firm can take ownership of the FLA filing as its first FEMA deliverable.

Not confirming the handover of digital credentials

GST portal, income tax portal, MCA portal, and FEMA FIRMS portal access are all registered to email IDs. If these are registered to the individual CA’s personal or firm email, the subsidiary does not have independent access to its own regulatory portals. A company without access to its own FIRMS portal cannot file an FC-GPR without the CA’s cooperation. Confirm credential ownership before initiating the handover conversation.

Treating the transfer pricing study as a standalone document

A transfer pricing study signed by a CA who has not reviewed the intercompany contract is a certification of a price without visibility into the arrangement being priced. When a transfer pricing officer reviews the documentation, they read the contract alongside the study. If the study uses different terminology, a different service description, or a different cost base than the contract, it creates an opening for an adjustment that the study was supposed to prevent.

Treelife practitioner note

In the cross-border engagements we have run at Treelife, the subsidiaries that transition to a full-service model smoothly are typically those that make the decision before a compliance event forces it, not after. The ones that come to us post-event are managing two problems simultaneously: the current filing and the historical gap. That combination is always more expensive to fix than either would have been on its own.

The pattern we see most often at the individual CA handover stage involves intercompany charges that have been running for 12 to 18 months without a signed agreement or a transfer pricing study. The CA was filing the income tax return and recording the charges as expenses. But without a transfer pricing study and a Form 3CEB, the expense deduction is vulnerable. Under Section 173 of the Income Tax Act, 2025 (formerly Section 92F of the repealed Income Tax Act, 1961), the burden is on the assessee to demonstrate that the price used was at arm’s length. Without contemporaneous documentation, the subsidiary cannot meet that burden even if the price was in fact reasonable.

The fix is not complicated. A retrospective transfer pricing study covering the open years can be commissioned, agreements can be executed with appropriate back-dating, and a Form 3CEB can be filed with a revised return where the assessment year allows. But the cost of remediation, in fees and penalty exposure, is considerably higher than the cost of having done it correctly the first year.

The second pattern is the CS gap. Subsidiaries where a practising CS was never engaged often have board meeting minutes that do not exist or were prepared after the fact, annual returns filed by the CA without CS oversight, and registers that have not been updated since incorporation. Under the Companies Act, 2013, the failure to maintain statutory registers attracts a penalty under Section 454 ranging from ₹25,000 to ₹5 lakh per default, with continuing defaults attracting additional daily penalties. These are the files that land in a due diligence data room and immediately signal to any investor or acquirer that the entity’s internal governance has not been maintained.

Frequently asked questions

Q: What is the difference between what a CA does for an Indian subsidiary and what a full-service firm does?
A: A CA handles tax filings, GST returns, audit, and financial statements. A full-service firm adds a practising CS for secretarial and MCA filings, a legal team for contracts and employment matters, and a transfer pricing specialist for intercompany transaction documentation. These are separate professional licences, not just different service lines.

Q: Does every Indian subsidiary with a foreign parent need a transfer pricing study?
A: Under Section 92 of the Income Tax Act, 1961, transfer pricing documentation is required for every international transaction. If aggregate international transactions exceed ₹1 crore, a Form 3CEB certified by a practising CA is also mandatory. The threshold is easy to cross: one management fee payment of ₹1 crore triggers it.

Q: How long does the handover from an individual CA to a full-service firm take?
A: A structured handover typically takes four to eight weeks. The main time driver is the compliance health check at the start, which determines whether retrospective filings or corrections are needed. A clean subsidiary with organised records can transfer in three to four weeks.

Q: What happens if the FC-GPR was filed late or not at all?
A: A late FC-GPR is a FEMA contravention. The subsidiary must apply for compounding with the RBI under Section 15 of FEMA 1999, read with the RBI’s Compounding of Contraventions under FEMA, 1999 directions. Compounding fees are calculated on the outstanding amount and the delay period. The process is manageable but should not be deferred because compounding fees accumulate daily.

Q: Can the subsidiary’s existing CA remain involved after transitioning to a full-service firm?
A: Yes, if both parties agree and the scope is clear. Some subsidiaries retain their individual CA for specific tax representation matters where the CA has an existing relationship with the assessing officer. The full-service firm handles the rest. Dual engagement requires a written scope split to avoid duplication and conflicting advice.

Q: What does the parent company’s overseas jurisdiction affect in terms of Indian compliance?
A: The parent’s jurisdiction determines the applicable DTAA for withholding tax on cross-border payments (royalties, technical fees, dividends, interest), the transfer pricing documentation requirements when comparable uncontrolled transactions are used, and the FDI sector classification under the consolidated FDI Policy (since certain jurisdictions trigger Press Note 3, 2020 requirements for prior government approval).

Q: Does a small subsidiary below ₹1 crore in revenue need a CS?
A: The secretarial obligations under the Companies Act, 2013 apply regardless of revenue. Board meetings must be held, minutes maintained, and MCA annual filings made. A private company with a paid-up capital below ₹10 crore is not required to appoint a whole-time CS but still requires CS services for statutory filings. A full-service firm provides CS services as part of the overall package rather than as a full-time hire.

Q: How does the FLA return differ from the FC-GPR, and why do subsidiaries mix them up?
A: The FC-GPR is a transaction-level filing made within 30 days of each share allotment to a foreign investor. The FLA is an annual balance sheet-level return filed by 15 July covering all foreign liabilities and assets as of 31 March. Confusion arises because both relate to the same foreign equity, but the FLA uses audited book values, not the transaction price. Using the wrong figure in the FLA is a common error.

Q: What if the individual CA refuses to hand over records?
A: Statutory records belong to the company, not to the CA. The CA has no legal right to withhold the client’s records, including books of account, tax filings, and supporting documents. If there is a fee dispute, it should be resolved separately. Most handovers proceed cooperatively. The subsidiary should maintain its own copies of all statutory filings from the date of incorporation.

Q: At what headcount does the legal workstream become unavoidable?
A: Employment law obligations apply from the first hire: an offer letter is a contract, and a termination without the correct notice or severance is a legal exposure. The legal workstream becomes more complex above five employees because at that point the Shops and Establishments Act registration, EPF and ESIC obligations, and the Prevention of Sexual Harassment (PoSH) policy requirement all apply. PoSH requires an Internal Complaints Committee (ICC) under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 for any entity with ten or more employees.

Q: Does switching advisory firms trigger a tax audit?
A: A change in CA or advisory firm does not trigger a tax audit. Audits are selected based on criteria set by the Central Board of Direct Taxes (CBDT), including return-level risk parameters and sector-specific scrutiny guidelines. A revised return or a compounding application may draw additional scrutiny but is not automatic.

Q: Does the parent seconding an employee to India create a tax problem for the parent?
A: It can. If the seconded employee exercises decision-making authority in India on behalf of the parent (such as finalising contracts or managing a dependent agent function), the parent company may have created a Permanent Establishment (PE) in India. That PE attribution exposes the parent to Indian corporate tax on profits attributable to the PE. The risk threshold is not high: even a visiting senior executive who signs contracts in India repeatedly can create a service PE if the visit pattern exceeds treaty thresholds (commonly 90 days in 12 months for unrelated parties, as low as 30 days for associated enterprises under some treaties). An individual CA managing the subsidiary’s payroll will not typically assess this risk. A full-service firm flags it before the secondment begins.

Q: Does the switch from the Income Tax Act, 1961 to the Income Tax Act, 2025 require any fresh filings?
A: The ITA 2025 is effective from FY 2026-27 onwards. Returns for FY 2025-26 and earlier assessment years continue under the old Act and the old section numbers. From FY 2026-27, section references on all filings, transfer pricing reports, and dispute correspondence shift to ITA 2025 numbering. The substantive transfer pricing obligations are unchanged. Form 3CEB continues in its current form while the tax authorities update the form nomenclature. Finance teams should confirm that their advisory firm has updated its filing templates to the new Act before the first return is filed for FY 2026-27.

Q: Can the full-service firm also coordinate with the parent’s auditors overseas?
A: Yes, and this is one of the practical reasons foreign parents prefer an integrated Indian team over individual advisers. The parent’s overseas auditors typically send a management representation letter and a request for subsidiary-level financial information during the group audit. An integrated Indian team can respond with audited financial statements, board-approved accounts, and intercompany reconciliations without requiring the parent’s CFO to chase three vendors in different cities.

Regulatory references:

• Foreign Exchange Management Act (FEMA) 1999
• Foreign Exchange Management (Non-Debt Instruments) Rules, 2019
• Income Tax Act, 2025: Sections 161 (TP general), 163 (international transaction, formerly S.92B ITA 1961), 165 (arm’s length price, formerly S.92C), 166 (reference to TP officer, formerly S.92CA), 171 (documentation, formerly S.92D), 173 (definitions, formerly S.92F); Form 145 and Form 146 (replacing Form 15CA and 15CB respectively, effective 01/04/2026)
• Income Tax Rules, 1962: Rule 10D (transfer pricing documentation, continues under ITA 2025)
• Companies Act, 2013: Sections 173(1), 139, 454
• Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013