Applicability of Transfer Pricing

TP provisions are applicable only if :

1. There is an associated enterprise as defined in section 92A e.g. foreign holding or subsy co. or group co., foreign associates, etc. AE has to be a NR, else TP provisions are N.A.
2. you enter into any International transaction as defined in section 92B which may be purchase or sale of movable or immovable properties, rendering of services, payment of royalty, taking or giving loans, sharing common expenses, or any other transaction with the AE.

Further, in case the TP provisions are applicable, you need to maintain the records prescribed under rule 10D and a record of each and every international transaction like invoices, loan agreements. Also submit a report of CA in Form 3CEB upto 30sep.

In case your case is referred by the AO to TPO, you also need to submit a detailed analysis of Arms length pricing, how it was arrived, profile of comaparable companies, assumptions made, etc. You may engage the services of a CA for this purpose.

Diff. in Transfer pricing regarding Direct Tax code with Income Tax Law??????????????

Direct Tax Code has been blocked and will not come into force.

So, we are supposed to go by the meaning & interpretation provided by Income Tax Act.

I agree with the answer posted by Mr. Navneet Gupta.