Transfer pricing and resident-nonresident transactions: determine India sourced income attributable to foreign branches under section 92. Section 92 empowers tax authorities to determine India sourced income from transactions between residents and non residents; Commissioners must examine assessments of Indian entities with foreign branches, liaison offices or subsidiaries, collect factual particulars (including RBI lists), apply section 92 where appropriate, and report detailed cases of escapement of income and modus operandi to the Board.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Transfer pricing and resident-nonresident transactions: determine India sourced income attributable to foreign branches under section 92.
Section 92 empowers tax authorities to determine India sourced income from transactions between residents and non residents; Commissioners must examine assessments of Indian entities with foreign branches, liaison offices or subsidiaries, collect factual particulars (including RBI lists), apply section 92 where appropriate, and report detailed cases of escapement of income and modus operandi to the Board.
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