Domestic Transfer Pricing

[krishna besta]

Dear All,

Please clarify Domestic Transfer pricing is applicable from which Financial Year and due date of fiilling of Incometax return of the DTP concers.

what are the consequences for DTP and if there is any circular or Notification please give the information.

Regards,

Krishna.B

[CAGOPALJI AGRAWAL]

GAAR (Chapter XA) is applicable from the assessment year 2014-15. Since there is a lot of hue and cry in this regards so the Govt. may roll back from the it.

[krishna besta]

Dear Sir,

 Transfer Pricing Comes under Section 40 A  and Section 10 AA ?. 

 Is it Transfer Pricing come under GAAR (Chapter XA) provisions ?.

[CAGOPALJI AGRAWAL]

If you are talking about 40A, it is not new section and is applicable probably from april 68.

AI Summary

Domestic transfer pricing: applicability queried; interaction with GAAR and expenditure disallowance provisions discussed. Domestic transfer pricing compliance and its commencement date for applicability and return filing consequences are queried. Replies associate the issue with General Anti Avoidance Rules and with established expenditure disallowance provisions and a separate tax incentive provision, noting GAAR was said to take effect in a later assessment year while disallowance provisions have long been operative; the thread records unresolved uncertainty and a request for formal circulars or notifications.