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2010 (10) TMI 21 - SC - Income Tax
Related companies - section 40A(2) - application of provisions of transfer pricing to domestic operations - Held that:- no interference is called for as the entire exercise is a revenue neutral exercise - In the case of domestic transactions, the under-invoicing of sales and over-invoicing of expenses ordinarily will be revenue neutral in nature, except in two circumstances - certain provisions of the Act, like Section 40A(2) and Section 80IA(10), need to be amended empowering the Assessing Officer to make adjustments to the income declared by the assessee having regard to the fair market value of the transactions between the related parties. - CBDT also asked to consider the issue