Job Title:  Manager | TP Advisory, Compliance, APA and Controversy management | Mumbai | Transfer Pricing

Job requisition ID ::  99071
Date:  Mar 31, 2026
Location:  Mumbai
Designation:  Manager
Entity:  Deloitte Touche Tohmatsu India LLP

Manager | Tax – Transfer Pricing | TP Advisory, Compliance, APA and Controversy Management

  • Location:  Mumbai


The team

Innovation, transformation and leadership occur in many ways. At Deloitte, our ability to help solve clients’ most complex issues is distinct. We deliver strategy and implementation, from a business and technology view, to help you lead in the markets where you compete. Learn more about our Tax Practice

 

Your work profile

As a Manager in our Transfer Pricing team you’ll build and nurture positive working relationships with teams and clients with the intention to exceed client expectations. You will work on following aspects:

 

Advisory:

  • Providing opinions in the form of memos, notes and presentations on    various transfer pricing issues 
  • Advisory services on Business Model Optimisation
  • Advisory on application to Profit Split Method Advisory services on Specified Domestic Transactions
  • Advisory services on cost allocations, cost contribution arrangements

 

Transfer Pricing advisory pertaining to business restructuring:

  • Review of inter-company pricing arrangements
  • Advising the client on possible transfer pricing exposures in relation to proposed international transactions
  • Review of costs allocation models

 

Advance Pricing Agreements (APA):

  • Assistance during all the stages of filing an APA application
  • Coordination and liasoning with the client and APA authorities
  • Preparation and review of APA applications

 

Compliance:

  • Preparation of transfer pricing documentation for various multinational client
  • Detailed understanding of the business profile and functions, assets and risks of clients
  • Research and analysis of the respective client industry
  • Identifying companies performing similar functions as of the clients using Indian and international database
  • Preparation of Form 3CEB 

 

 

Audit proceedings:

  • Handling transfer pricing assessments and appeals (at Transfer Pricing Officer,
  • Dispute Resolution Panel, Commissioner of Income-Tax (Appeals) and Appellate Tribunal level)
  • Compiling information required for preparation of submissions, and for providing clarifications that may be required by the Revenue authorities
  • Preparing written submissions, as required, in connection with the revenue proceedings involving Analysis of various case laws
  • Time to time representations before the Revenue authorities
  • Assisting the legal counsel in representing at the Tribunal Level
  • Assisted in drafting submissions and representing at the Tribunal Level

 

Others:

  • Effective project and time management
  • Preparing presentations for various summits and conferences
  • Given presentations in Firm's offsite
  • Balanced allocation of work to team members
  • Guiding and developing team members
  • Development / promotion of the Deloitte Tax brand name – articles in publications, speaker at seminars, etc.
  • Knowledge sharing with the team members including recent case laws, news articles, journals, etc.
  • Training new joiners in the team

 

 


Key skills required: 

  • CA or MBA Finance Primer Institutes
  • 5 – 7 years of Experience in Transfer Pricing
  • Strong Technical knowledge
  • Analytical skills & conceptual clarity
  • Innovation and creative thinking
  • Effective communication and presentation skills
  • Time and cost management
  • Managing and leading a team
  • Mentor for professionals