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Technology & Software Services | Case Study | N D Savla & Associates

Technology & Software Services

An Indian subsidiary of a USA-based ERP firm with 80%+ related-party revenue and operations across two states — we delivered a TP-ready audit and harmonized labor compliance across jurisdictions.

Client Type ERP & Software Implementation | Parent: USA-based

Industry Software / ERP Implementation

Engagement Statutory Audit | Transfer Pricing

Duration Annual Engagement

The Challenge

What the engagement demanded.

Indian subsidiary of a USA-based ERP software firm. Operations span Maharashtra and Gujarat with a large headcount. Over 80% of revenue comes from the USA-based parent (related party), creating Transfer Pricing complexity. Multi-state labor compliance (Professional Tax, PF, ESIC, MLWF), notional GST on foreign income flows, and Forex management for inward remittances added further layers to the audit.

Our Approach

How we executed the engagement.

01

Transfer Pricing Documentation

Master File, Local File preparation, and Country-by-Country Reporting awareness for the global group.

02

Arm's Length Pricing

TNMM benchmarking with comparable Indian software service providers, applied to related-party revenue.

03

Multi-state Labor Audit

Professional Tax (Maharashtra and Gujarat), PF, ESIC, MLWF — coordinated across both states.

04

Forex Tracking

Inward remittance reconciliation, FIRC matching, and forex gain-loss recognition.

05

Notional Service GST

Reverse Charge Mechanism review and deemed supply analysis for cross-border services.

Expertise Delivered

The capabilities we brought to bear.

Transfer Pricing Strategy

TP study preparation, comparables benchmarking, and Form 3CEB filing with correct method selection.

Revenue Recognition

Contract-based, proportionate-fulfillment basis under Ind AS 115.

Multi-state Labor Compliance

Coordinated PT, PF, ESIC, MLWF compliance across Maharashtra and Gujarat operations.

Forex Management

Realized and unrealized forex gain/loss tracking, FIRC reconciliation.

Foreign Income Taxation

DTAA application, withholding tax claims, and credit reconciliation.

Key Outcomes

The results we delivered.

TP-ready compliance with Form 3CEB filed accurately
Labor compliance harmonized across MH and GJ operations
Forex P&L correctly stated with full FIRC reconciliation
DTAA claims processed for withholding tax credits

“At N D Savla & Associates, we don't just ensure compliance — we help you make smarter financial decisions with clarity and confidence.” — N D Savla & Associates

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