What auditors actually ask for
The first week of a transfer pricing audit is a document request. Produce the Local File, the Master File, the search strategy, the accept/reject matrix, the financials used for the tested party, and the working papers behind the range. Teams that stored those pieces in five folders and a dead mailbox spend that week reconstructing history. Teams that generated them in one workspace spend that week answering the characterisation question.
TP audit and litigation support, in product terms, is the ability to replay the study. FAR comparable scoring in TP DOC GEN AI is 0–100 across four equally weighted criteria (industry, functions, risk, operations), each with a written rationale grounded in live web search. The accept/reject matrix is reconstructed from the database export rather than typed into Excel after the fact. Instant PLI keeps a worksheet with blocking validation: operating profit must equal operating revenue minus operating cost, or the result is rejected.
That is not a courtroom argument. It is the hygiene that makes a courtroom argument possible. SBC's controversy practice still handles MAP, APA, and litigation. The platform's job is to stop the file from becoming the first exhibit against you.
Week one of an audit is won or lost on whether those artefacts open. If they do, you argue characterisation. If they do not, you spend the week reconstructing history while the officer writes the next information request. Software cannot make a weak FAR strong. It can make the packet exist on the day the notice arrives, which is the only day that counts.
Bounded outputs you can put in a hearing bundle
Audit officers are not impressed by fluent paragraphs. They are impressed by a range they can re-perform. AI in this product is bounded on purpose. Narrative: drafted. Numbers: code. Statutory citations: code. Digit sequences in translated Local Files: validated, or the fragment stays in English. Entity legal names, citation numbers, database names, and currency codes are never translated.
Deterministic Instant PLI mode is on by default: same document in, same ratios out. Classification rules override the model for known line items, and every override is audit-trailed. If one AI vendor fails, generation retries on the other. None of that is a substitute for a partner review. All of it is a substitute for "the intern copied last year's wording."
When a notice arrives, export the report, the annexures, and the PLI workbook. Walk the officer through the search steps in the same order the platform recorded them. That is TP audit support as infrastructure, before it is TP audit support as advocacy.
Litigation-adjacent work the file must already contain
Litigation and MAP turn on contemporaneous documentation. A study prepared after the assessment order is a different, weaker animal in most forums. The Local File's economic analysis chapter, the FAR, and the comparables list need to have existed when the return was filed. The platform's job during the season is to make that contemporaneous file cheap enough to actually produce.
SBC's advisory side covers representation in audits, MAP, APAs, and litigation across India, the UAE, and other jurisdictions where we practise. We will not list fake win rates or unnamed "global corporations." If you need counsel, that is a conversation on the walkthrough, not a badge on this page.
Read how a Local File functions as audit defense, or how client data is handled when a file leaves your laptop. To see a reconstructable study on a scenario you choose, book a specialist walkthrough.
What the tool will not do in a dispute
It will not file a submission. It will not predict assessment outcomes. It will not invent comparables that failed the screens. It will not silently "fix" a PLI that does not reconcile. Those constraints are the point. A hearing bundle full of unexplained model output is a gift to the other side.
Use the platform to keep the working papers honest. Use SBC (or your own controversy team) to argue the law. That split is how TP audit and litigation support should be staffed in 2026.
Archive the export, the PLI workbook, the search extract, and the collaborator log when the return is filed. If a notice arrives eighteen months later, you should not be hunting a dead mailbox. MAP and APA files will reuse the same FAR and range; they will not reuse a reconstructed Excel that no longer matches the Local File.
We do not claim the software files a reply or predicts an assessment. We do claim that a reconstructable study is cheaper to produce on time than to rebuild under a deadline. That is the only honest product sentence in a controversy conversation.