Yes. Any transaction between your Indian company and its foreign parent or group entities — software development services, management fees, cost reimbursements, IP licensing — is an international transaction with an associated enterprise, and must be at arm's length under Indian transfer pricing law.
Practically this means: a written intercompany agreement, a defensible margin (many India–US service subsidiaries operate on a cost-plus model), an annual accountant's report in Form 3CEB, and documentation supporting the pricing where thresholds are crossed.
Transfer pricing is not optional paperwork — it determines how much profit is taxed in India versus the US, and both tax authorities look at it. Set the model when the structure is created, not at the first audit.
