Special provision for transactions with entities in notified jurisdictional areas mandates related party treatment and documentation, and requires withholding on payments. Transactions with persons in a notified jurisdictional area are deemed related party international transactions for transfer pricing: parties are treated as associated enterprises and a wide range of dealings including property transfers, services and financing fall within the deeming provision. Payments to financial institutions in such jurisdictions require an authorisation in Form No.10FC and evidence of deposit to the institution and the assessing officer. Assessees must maintain enhanced documentation-ownership structure, group profile, business description and other relevant information-and face disallowance of deductions or deeming of receipts as income if explanations about source or beneficial ownership are unsatisfactory.
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.
Special provision for transactions with entities in notified jurisdictional areas mandates related party treatment and documentation, and requires withholding on payments.
Transactions with persons in a notified jurisdictional area are deemed related party international transactions for transfer pricing: parties are treated as associated enterprises and a wide range of dealings including property transfers, services and financing fall within the deeming provision. Payments to financial institutions in such jurisdictions require an authorisation in Form No.10FC and evidence of deposit to the institution and the assessing officer. Assessees must maintain enhanced documentation-ownership structure, group profile, business description and other relevant information-and face disallowance of deductions or deeming of receipts as income if explanations about source or beneficial ownership are unsatisfactory.
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