Domestic transfer pricing related

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

21 November 2013 Dear All,

Pls help me in understanding DTP.
Two clients of ours are falling within the perview of Sec 92E.

we have identified the associated concerns, but for proceeding with Specified Domestic transactions, does it have impact only for those concerns which have Chapter VIA deductions ??? Pls confirm becoz our clients dont have any sought of deductions from Total Income.

If my view is wrong, pls correct and provide the correct provisions.

Its urgent. Pls help.

Nikhil Kaushik

Nikhil Kaushik (Expert)
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22 November 2013 no.. it shall have impact irrespective of chapter VIA deductions.

you need to the appropriate ALP to minimize the tax risks your clients may face due to TP adjustments.

Querist : Anonymous

Querist : Anonymous (Querist)

22 November 2013 Thanks Mr.Nikhil we shall start out audit.
Can u share any audit plan kind of thing for DTP.

Once again thank you for the inputs.

Nikhil Kaushik

Nikhil Kaushik (Expert)
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22 November 2013 for transfer pricing it is more of transactional analysis. so plan has to be a very customized one.

Querist : Anonymous

Querist : Anonymous (Querist)

22 November 2013 Dear Nikhil,
Once we have identified the Asso. Enterprise(AE), we need to 1st chk on whether aggregate amount of all SDT (specified domestic trans) exceed Rs.5 cr, and only those AE of all should be taken up for review of ALP.
Does SDT include all of these: Pur,Sales,Int free Loan, Buniess related exp. Pls confirm my understanding. Thanks.

Nikhil Kaushik

Nikhil Kaushik (Expert)
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22 November 2013 you are correct. For what transaction are covered under Domestic TP, please refer section 92BA

Querist : Anonymous

Querist : Anonymous (Querist)

22 November 2013 Thanks aton

Nikhil Kaushik

Nikhil Kaushik (Expert)
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22 November 2013 you are welcome.

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