Transfer pricing

Vinetha (Article Assistant) (29 Points)

12 October 2012  

I have some doubts regarding the applicability of Transfer Pricing

In case of :-x ltd co incorporated in India running business of Software development renders their entire service to a single party which is a co. incorporated in USA. The shareholding pattern of these companies is as follows

In indian co a person has 79% share holdings

The share holder having 60% share holdings in US co. is a relative(Son) of the above shareholder .

The above shareholder(in US co)  is one of the directors in the Indian co. having no share holdings in Indian co.

Whether the above mentioned two companies will be deemed as Associated Enterprises?