Transfer pricing

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Querist : Anonymous

Querist : Anonymous (Querist)

03 October 2012 If transfer pricing is applicable to Individual also then why ITR-4 does not contain any question regarding "Are you liable to furnish 92E"

Thank you

Aditya Maheshwari

Aditya Maheshwari (Expert)

03 October 2012 Transfer pricing not applicable to individuals.

Querist : Anonymous

Querist : Anonymous (Querist)

04 October 2012 Dear Aditya Sir

The definition of associated enterprises of transfer pricing includes individuals,HUF who enters into international transaction with his/or his
enteprise(in another country) then such transaction will be covered under TP
Accordingly,it indirectly means to me it is applicable.

Please Clarify

Thank you

Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)

02 August 2025 Great question! Here’s the clarity on Transfer Pricing (TP) applicability for individuals:

* **Transfer Pricing rules generally apply to "associated enterprises" engaged in international transactions.**
* An **individual or HUF can be considered an associated enterprise** *only if* they have a business or enterprise that has cross-border transactions with a related foreign enterprise.
* However, **most individuals who file ITR-4 are presumptive taxpayers with small businesses or professionals** and typically do **not have international transactions requiring TP compliance**.

**Why ITR-4 does not ask about Form 92E or TP?**
Because:

* Form 92E and TP documentation is mandated only if you have international transactions above specified thresholds.
* Individuals filing ITR-4 generally do not fall in this category.
* TP compliance is mainly relevant for businesses with significant cross-border dealings, often filing ITR-3 or ITR-5/6.

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**In short:**
TP *can* apply to individuals with international transactions but is rare, and ITR-4 is designed for simpler tax returns, so it doesn’t include TP-related questions.

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If you or someone you know has cross-border transactions as an individual or HUF, they should ideally file ITR-3 and comply with TP rules including Form 92E.

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