dear all
a company abc ltd. is the indian subsidiary of an american co. manufacturing and selling copier machines.the indian co. among other things purchases and sells these copier machines also.does any part of the profit on the sales of american co. to the indian company accrue or arise in india u/s 9(1)(i).
thanks & regards
tarun rustagi
Dear Tarun,
Board has issued number of circulars under Sec 9 where the Purchase/sale of goods are kept outside the purview of "business connections".
But since it is a transaction between associated enterprize therefore "transfer pricing" provisions will be attracted & any undue benefits to Foreign parent shall be reversed...
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