Hi,
My company is an MNC headquartered in India. We make transfers to our group companies abroad. For this purpose we get Form A2 duly approved. Recently we got a notice from IT dept u/s 133(1) asking us to list all the foreign outward remittances and whether TDS has been deducted. These transfers are purely for business purposes (working capital) and not in the nature of capital contribution( in which case prior RBI approval is necessary) . My doubt is will the Assessing officer question on the end use of these funds transferred. I know it is a crazy doubt, but supposing Salary has been paid out of these funds by our group co abroad. Will it be deemed to be accruing or arising out of India and 192B applicable thereon. Is there any transfer pricing angle to it (we dont buy or sell goods ),,Before giving the info I wanted to know the intention of the AO!! Can someone help me?!!
CAclubindia
