The Indian government and tax authority view transfer pricing as a way of collecting more taxes, rather than acting as a deterrent for abusive tax structures. Transfer pricing provisions are invoked by the tax authority in almost all transactions above a certain threshold through a set of rules.

There is no qualitative screening of transactions before they are picked up for scrutiny. As a result, India alone counts for more than 70% of the transfer pricing disputes worldwide and in 2016, there were more than 600 reported cases on transfer pricing from India.