Transfer pricing applicability
This query is : Resolved
16 September 2011
Whether Transfer pricing will be applicable in relation to the transactions with Branch located in Taiwan....
Transactions are entered with its own branch only...For transfer pricing purpose, branch has to be considered as a separate enterprise?????
Transactions are entered with its own branch only...For transfer pricing purpose, branch has to be considered as a separate enterprise?????
16 September 2011
Transfer Pricing is applicable only when transaction between associated enterprises during the financial year. Extract of relevant sections for the definition of “associated enterprises”.
92A(2) two enterprises shall be deemed to be associated enterprises if, at any time during the previous year,—]
clause (a) one enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in the other enterprise; or
clause (b) any person or enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in each of such enterprises;
92A(2) two enterprises shall be deemed to be associated enterprises if, at any time during the previous year,—]
clause (a) one enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in the other enterprise; or
clause (b) any person or enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in each of such enterprises;
You need to be the querist or approved CAclub expert to take part in this query .
Click here to login now
Click here to login now
Similar Resolved Queries
Unanswered Queries
- About TDS & Income Tax
- Under construction property in ITR
- Section 194JA & JB Income which ITR Form to use
- Scrutiny and reopening of past returns
- Pass word to open justification report for Q1 for FY 2026-27
- PPF interest-As Exempt Income disclosure
- Upload Level ValidationITR3Category of Defect B/D
- Booth for sales promotion
- Building tax payment deduction in rental Income
- Not able to file ITR
- TAX AUDIT QUESTION
- VALUATION OF PRIVATE LIMITED COMPANY SHARES
- LIABILITY ADJUSTMENT
- Capital Gains on sale of residential flat
- Accounting with Claude
- PF Taxable Income
- Clarification on Tax Audit Applicability and Reporting of F&O Transactions in ITR-3
- Interest credited in FY2025-2026 & TDS therein by EPFO does not reflect in AIS or Form 26AS
- 44ad eligble money lending interest
- Delisted shares sold in off market/ Rebate u/s87A
Trending Online Classes
-
DT & Audit (Exam Oriented Fastrack Batch) - For May 26 Exams and onwards Full English
CA Bhanwar Borana & CA Shubham Keswani
Subscribe to Pro
Join an elite circle of professionals
CAclubindia
