CA in service & CS. dipmaj@
3492 Points
Posted on 25 September 2012
If you have any 'international transactions' with 'Associated Enterprises'(AE) then section 92E is to be complied with.
In brief, generally, the foreign related parties are AE.
Any transaction like purchase, sale of tangible / intangible goods, rendition of services , borrowings taken or given would fall within the purview of international transactions.
Besides 3CEB, you need to prepare and maintain a documentation report under rule 10D about the TP method used to determine ALP.
Regards,