Transfer pricing_ associated enterprise

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vijay kumar (Querist)

12 June 2014 Dear Experts,

Our company is a manufacturing company in the filed of Oil and natural gas. We got a work order from a foreign company based in Italy. As per work order, we have to manufacture spare parts as per their specifications and has to sell the same to them at the end of the prescribed period.

Now my query is , by virtue of this work order, shall our company and the said foreign company will become "Associated Enter Prises" as per Sec 92A(2)(i)?

if so, what will be the best suited method for determining ALP?

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 no. asssociated enterprises are defined under section 92A. please check whether your company and the italian company are associated enterprises or not.

vijay kumar

vijay kumar (Querist)

13 June 2014 Sir,

Will these co,s become " deemed associated enterprises" by virtue of subsection 2 of section 92A which is reproduce here for your ready reference/

If, so whether our company needs to obtain certificate in form 3CEB in addition other discloure requirements?

The goods or articles manufactured or processed by one
enterprise, are sold to the other enterprise or to persons specified by
the other enterprise, and the prices and other conditions relating
thereto are influenced by such other enterprise.

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 can we covered under 92A(2)(i).

in such a circumstance, 3CEB report would be required.

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vijay kumar

vijay kumar (Querist)

13 June 2014 Thanks you very much for resolving the issue.

Nikhil Kaushik

Nikhil Kaushik (Expert)

13 June 2014 you are welcome friend......

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