Transactions with persons in notified jurisdictional areas treated as associated enterprises, triggering transfer pricing and deduction controls. Transactions with persons in notified jurisdictional areas are deemed to involve associated enterprises and to be international transactions, thereby invoking the transfer pricing provisions (sections 92, 92A, 92B, 92C [with one exception], 92CA, 92CB, 92D, 92E and 92F). Deductions for payments to financial institutions require prescribed authorisation to obtain information; other deductions require prescribed documentation. Unexplained sums received from such persons may be taxed as the assessee's income, and tax deductible under Chapter XVII-B must be withheld at the highest applicable rate.
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Provisions expressly mentioned in the judgment/order text.
Transactions with persons in notified jurisdictional areas treated as associated enterprises, triggering transfer pricing and deduction controls.
Transactions with persons in notified jurisdictional areas are deemed to involve associated enterprises and to be international transactions, thereby invoking the transfer pricing provisions (sections 92, 92A, 92B, 92C [with one exception], 92CA, 92CB, 92D, 92E and 92F). Deductions for payments to financial institutions require prescribed authorisation to obtain information; other deductions require prescribed documentation. Unexplained sums received from such persons may be taxed as the assessee's income, and tax deductible under Chapter XVII-B must be withheld at the highest applicable rate.
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