The proceedings to determine arm’s length price specifically in terms of the international / specified domestic transactions may be referred to a specialist tax officer, referred as the Transfer Pricing Officer (“TPO”). Upon determination of the arm’s length price TPO...

Section 92E pertains to annual accountant’s report as required to be furnished by every person who has entered into international related party transactions or specified domestic transactions (>INR 20 Crores ~ 30,750 USD) during the relevant financial year.

Section 92D pertains to documentation required to be maintained for TP compliance purpose under the Indian TP provisions. The section along with relevant Rules i.e. Rule 10D and 10DA of Income Tax Rules, 1962 provides details of the documents that are required to be ma...

Section 92C pertains to “Computation of Arm’s length price” under the Indian TP provisions. This section is most vital as far as application of Indian TP provisions is concerned. Once the applicability of Indian TP provisions has been determined with reference to Secti...

Key proposals under the Finance Bill 2018 pertaining to Transfer Pricing provisions in India.

Section 92B and 92BA pertaining to “Meaning of international transaction” and “Meaning of specified domestic transactions” respectively, are key sections determining the scope of TP legislation in Indian Tax Framework. These sections provide the definitions of cross-bo...

Section 92A pertaining to “Meaning of Associated Enterprises” is a key Section of TP legislation in Indian Tax Framework. This section, defines “Associated Enterprises”, i.e. the business entities upon whom the transfer pricing provisions in India are applicable.

Section 92 pertaining to the computation of income from international transaction is the charging section incorporating the transfer pricing legislation in Indian Tax Framework. The section, as stands today, was inserted vide Finance Act 2001 and was later amended vide...

Indian TP provisions were introduced by the Finance Act 2001, and have ever been evolving to keep pace with the global developments. It gives us immense pleasure to introduce our new Bulletin series, covering TP topics. It would be our endeavor to keep you abreast with...