tranfer pricing

hey frnds...
the parent company is indian company & its subsidary company is in uganda.. subsidary company in uganda has been received from indian parent company... so indian company has received interest income from its subsidary... also tds has been deducted by uganda subsidary @ 10% as per DTAA agreement.

the question is how to treat this income by indian parent company in income tax return and whether transfer parcinig provision is applicable or not?? tds deducted buy uganda subsidary company is allowable as tax credit or not..

reply its urgent..

Replies (1)

whenever there is transaction between associated enterprises, tranfer prising provision applicable.

here it is also apply and we have to see rate at which loan is given by indian co. to other non associated enterprise and that rate shall be Arms lengh price and AO shall recalculate interest income at that rate if rate is higher. but if that rate is lower then 10% shall b arms lengh price b coz transfer pricing provision shall not apply if application of that provision is reduce income which is declare by person.'

and Tds credit shall available.

Leave a Reply

Your are not logged in . Please login to post replies

Click here to Login / Register  

Company
20 September 2026
Semi Qualified CA

Navin & Associates

Mumbai

CA Inter

View Details
Company
08 September 2026
Audit Executive

Thammana & Associates

Srikakulam

B.Com

View Details
Company
ARTICLESHIP 18 September 2026
Industrial Trainee

Twenty Point Nine Five Ventures Private Limited

Noida

CA Inter

View Details
Company
ARTICLESHIP 25 August 2026
CA Article's

Saini Pati Shah & Co LLP

Mumbai

CA Inter

View Details
Company
ARTICLESHIP 16 September 2026
CA Article Trainee

SR BAGAI & Co.

New Delhi

CA Inter

View Details
Company
15 September 2026
Client-site CA associate

Aditya Muley and Co

Mumbai

CA

View Details
Company
ARTICLESHIP 04 September 2026
Accounts Executive

Hema Yashwanth & Associates

Chennai

B.Com

View Details
Company
09 September 2026
Semi Qualified CA / CA Inter - 2 Groups Cleared

Getmyca Consultant Pvt Ltd

New Delhi

CA Inter

View Details