banner_ad

Application for Advance Ruling - transfer pricing

This query is : Resolved 
Profile Image

Profile Image

(Querist)
23 January 2025 Hello everyone,

A ltd is 100% subsidiary of a german company incorporated in the year 2022-23 (captive unit) to provide IT services to its parent/group companies from India.

they are billing @ cost+13%. However consultant has opined that industry margin is 18-20%.

My question
1. Is it advisable to file application before AAR ?
2. I am worried that if order is unfavourable then AO may make primary adjustments for 22-23 and 23-24 as well even though we have TP report from reputed auditor ?
Profile Image

Gopalkrishna Hegde ,CA,DISA

Profile Image

Gopalkrishna Hegde ,CA,DISA (Expert)
15 February 2025 I feel it is better not to go for AAR. Just wait for the assessment to get completed. However if you feel that better not to get into litigation you may consider higher markup percentage.
You need to be the querist or approved CAclub expert to take part in this query .
Click here to login now


CCI Pro
Join CAclubindia WhatsApp Finance Community & stay updated with the latest TAX news, compliance alerts and important updates all in one place!


Similar Resolved Queries


loading


Unanswered Queries


banner

Trending Online Classes

view all classess

CCI Pro
Meet our CAclubindia PRO Members
Subscribe Now

Follow us
add to google news



Answer Query



Quick Links



Browse by Category




Latest Job Openings

View all
Company
ARTICLESHIP 27 May 2026
CA Article Trainee

Rahul Dang & Associates-Chartered Accountants

Pune

CA Inter

View Details
Company
Featured 28 May 2026
SEMI QUALIFIED/ CA DROPOUTS/ ARTICLES

T R SOOD & CO

New Delhi

CA Inter

View Details
Company
26 May 2026
Education Content Creator

Adyayam Education LLP

Bengaluru

CA Foundation

View Details
Company
29 May 2026
Finance Head

Bhawar Sales Corporation

Chennai

Graduate (Any)

View Details
Company
24 May 2026
Accounts & Tax Executive

PARAS KHURANA AND CO

New Delhi

B.Com

View Details
Company
14 May 2026
Financial Analyst - Remote Finance Expert

HiringBridge

Ahmedabad

CA

View Details
Company
ARTICLESHIP 15 May 2026
Audit Assistant / Article Trainee / Intern

SSGS and Associates

Chennai

CA Inter

View Details
Company
14 May 2026
Senior Associate

ABHISHEK SHANKAR AGARWAL & ASSOCIATES

Kolkata

CA

View Details