05 December 2021
ABC Private Limited a foundry unit has sold castings worth Rs. 20.50 crores to XYZ Private Ltd during FY 20.21. Directors of both the companies are same. XYZ Private Ltd. has paid Rs. 3.00 crores to the directors and their sons as salary and interest on deposit. Total payment to related parties covered u/s 40A (2) (b) exceed 20 crores. ABC Private Limited also generates solar power and claimes deduction u/s 80IA. The querry is whether Domestic Transfer Pricing provisons are applicable to XYZ Private Ltd for AY 21.22 in view of amendments made in 2017.