Query regarding transfer pricing

Dear Experts,

 

Greetings!!!

I am looking for your valuable suggestions for International Transfer Pricing documentation for below said case:

Ex.

Group A – Indian Partner

Grout B – Foreign Partner (Formed by Group C)

Group C – Foreign Supplier

Group A of India and Group B from foreign partner have incorporate an Private limited company in India. The Group B is Holding Company formed by the Foreign Suppliers Group C.

If newly incorporated company made purchase of goods from Group C is required Transfer Pricing Rules as per Income Tax Act and regulations in India. Group C is neither an investor nor stake holder in newly formed company but they have formed new Holding Company at their country and invest in newly formed company.

If we require following the transfer pricing procedure, let me suggest the list of documents and procedure of the same.

Take liberty to greeting thanks in advance for spend your precious time to read my query and valuable suggestions.

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