Is transfer pricing applicable only when transaction is between related parties of different countries.
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Quick Summary
This discussion clarifies the scope of transfer pricing. It confirms that transfer pricing regulations are not limited to transactions between related parties in different countries. The rules also extend to specified domestic transactions within the same country. Furthermore, major agreements with unrelated parties can also be considered deemed international transactions under Section 92B(2).
Yes you're right Abhishek. We generally follow a practice of checking the major agreement with unrelated parties which may be covered under the ambit of deemed international transaction (foreign as well as Indian company) u/s. 92B(2).
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