Subramanya Bhat (CA) 14 August 2020
One of our clients is 100% subsidiary of a foreign company and provide services (export) only to the foreign parent company. For this there is a contract where they raise an invoice on monthly basis to the parent company which has a markup of 15%.
Due to unforeseen business reasons our client will not be providing any services for till end of the year and hence no invoice will be raised. From Transfer pricing Income tax point of view, will there be any challenges? Will Income Tax department, based on the contract consider any deemed income?
Thanks you in advance.