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International Taxation, Income Tax

Issue Id: - 114333
Dated: 21-11-2018
By:- CA.LALIT MUNOYAT
International Taxation

  • Contents

Sec 92 92A 92F etc.

An Individual holds 95% of the share capital of a company in the UK. He has given an interest free loan to it without interest. Whether Transfer pricing adjustment on account of interest will be made to the income of the individual. The loan has been given out of the savings of the individual without borrowing any sum from the market.? Whether the Individual who is not engaged in any other business in India except as a MD of a company wherein also he holds 95% of the equity, be treated as "enterprise" so as to be covered in the definition of "Associated Enterprises. . The sources of his income are: Salary as MD, Income from House Property, Dividend etc. (No business Income)

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Showing Replies 1 to 2 of 2 Records

1 Dated: 21-11-2018
By:- DR.MARIAPPAN GOVINDARAJAN

In my view transfer pricing adjustment will be applicable.


2 Dated: 6-1-2019
By:- kollengode venkitaraman

AS THERE IS NO INCOME FROM"BUSINESS/PROFESSION' TRANSFER PRICING RULES ARE NOT APPLICABLE


1

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