TP Doc Gen AI: transfer pricing benchmarking and documentation for India and the UAE →

Deterministic math

Numbers you can defend, line by line.

AI reads the accounts. Every margin, percentile and range after that is computed in code, the same way every time, and each one shows its working.

Illustrative figures, 15 comparables.

India’s range

Read at a place, not between two.

Rule 10CA defines each percentile as a place in the sorted set. So each bound is a real comparable’s margin, or the mean of two neighbours, and Annexure 5 prints the place it came from.

Comparable margins, sorted · 15 companies

  1. Place 14.12%
  2. Place 25.38%
  3. Place 36.05%
  4. Place 46.71%
  5. Place 57.29%
  6. Place 67.84%35th
  7. Place 78.12%
  8. Place 88.66%Median
  9. Place 99.21%
  10. Place 109.78%65th
  11. Place 1110.43%
  12. Place 1211.27%
  13. Place 1312.15%
  14. Place 1413.08%
  15. Place 1514.86%

How each bound is read

  • 35th15 × 35 ÷ 100 = 5.25 → place 67.84%
  • Median15 × 50 ÷ 100 = 7.5 → place 88.66%
  • 65th15 × 65 ÷ 100 = 9.75 → place 109.78%
Illustrative margins. Places computed by the product’s own rule.

Where AI stops

The model reads. Code does the sums.

AI reads the audited accounts and cites the page each figure came from. From there, operating profit, every margin and the range are computed in TypeScript. No language model produces a number in the result.

  • Revenue from operationsRead by AI[Audited P&L p.6]842,650,000
  • Other incomeRead by AI[Audited P&L p.6]12,480,000
  • Finance costRead by AI[Notes to accounts p.21]9,340,000
  • Operating profitComputed in codePBT + finance cost − other income64,960,000
  • Operating mark-upComputed in codeOP / OC8.35%
  • 35th percentileComputed in codeRule 10CA, place 67.84%
Illustrative figures.

The operating split

Operating profit that ties to the statement.

Operating revenue leaves out other income, and operating cost leaves out finance cost. Operating profit is bridged from profit before tax, so it reconciles to the accounts rather than to a line someone typed.

  • The engine lists 13 non-operating income items and 11 non-operating expense items, each with its Ind AS and IFRS name.
  • For a bank, an NBFC or a treasury company, interest income stays operating.
  • The same P&L gives the same figures in the IRD, Instant PLI and a benchmarking study.

Operating revenue

Total income
855,130,000
−Other income
12,480,000
=Operating revenue
842,650,000

Operating profit

Profit before tax
68,100,000
+Finance cost
9,340,000
−Other income
12,480,000
=Operating profit
64,960,000

Operating cost follows as operating revenue less operating profit: 777,690,000.

Illustrative figures.

Profit level indicators

Every ratio shows its working.

The engine computes 17 ratios from the accounts, from operating mark-up to the Berry ratio. Each one shows its numerator and denominator, so a reviewer can redo it by hand.

  • CUP and profit split are compared on price or contribution, not computed from the accounts.
  • Operating Mark-upOP / OC = 64,960,000 ÷ 777,690,0008.35%
  • Operating MarginOP / OR = 64,960,000 ÷ 842,650,0007.71%
  • Gross MarginGP / Revenue = 244,350,000 ÷ 842,650,00029.00%
  • Berry RatioGP / OpEx = 244,350,000 ÷ 179,390,000136.21%
  • EBITDA MarginEBITDA / Revenue = 83,720,000 ÷ 842,650,0009.94%
  • Employee Cost RatioEmpCost / OC = 96,420,000 ÷ 777,690,00012.40%
Illustrative figures.

Reproducible

The same answer, every time.

Rounding is half to even: four decimals while computing, two on screen. The engine is tested against hand computations on real published accounts, and every India bound against the place it cites.

Half to even, at two decimals

12.345
12.34
12.355
12.36
12.365
12.36

What the engine’s tests check

  • Operating revenue, cost and profit tie to the filed statement of real Indian annual reports.
  • Operating margin and mark-up tie to the hand computation.
  • The same P&L gives the same operating figures on every screen where it is entered.
  • Each India bound equals the margin at the place it cites.
Rounding values illustrated.

Coverage

What it covers.

Ratios
17 computed
From operating mark-up to the Berry ratio
🇮🇳 India
35th – 65th
Rule 10CA data places, six or more comparables
🇮🇳 India, under six
Arithmetic mean
Judged with the tolerance band
🇦🇪 UAE
25th – 75th
Interquartile range, interpolated. OECD sets use the same.
Tolerance band
1% or 3%
India: wholesale trading, or other transactions
Rounding
Half to even
Four decimals computed, two shown

Questions

Before you ask.

Can I check a ratio by hand?
Yes. Each profit level indicator shows its formula with the numerator and denominator it was computed from.
Why doesn’t the India range match Excel’s PERCENTILE.INC?
Rule 10CA reads each percentile at a data place rather than interpolating, so each India bound is a real comparable’s margin, or the mean of two. UAE and OECD ranges do interpolate, the way PERCENTILE.INC does.
What happens when a denominator is negative?
The ratio is not shown as a percentage, because a margin over a negative base cannot be read. It shows as a dash with a warning, and the value is kept for review.
Where do exchange rates come from?
The FX tool converts at a published rate and shows its source and as-of date beside the result, ready to cite.

Book a demo

Bring us last year’s study.

We’ll run it through intake, benchmarking and the report while you watch. Whatever comes out is yours to keep.

Prefer email? Use Contact us.