Finance Forward

The payment of management fees falls under the intragroup services that are being availed by the associated enterprises. Here I am going to discuss the striking point for the transfer pricing officer w. r. t. this transaction while doing the TP Audit.  In one of the cases the assessee had been showing the payment of management fees to its associated Enterprises outside country and for three years in continuation the transfer pricing officer made an adjustment on account of payment of management fees which was determined at a basic minimum as it was discussed by TPO in the order that such huge amount of payment fees is not required to be made. Further it was ascertained by the transfer pricing officer that this payment of management fees falls under the category of shareholder activity.  Subsequently for two assessment years it was seen that there was no transfer pricing reference made in the case under section 92CA(1). During the course of transfer pricing audit it was noticed...

Hello everyone Hope you all are Leading a focused life with clear written goals. They are so very important in bringing clarity in what you are doing and what we plan to do. I just thought of penning my thoughts down as I am at such an important juncture of my life wherein I have to take some very important decisions which would mark a new beginning and Pave a way for my future. Seven years in Mumbai have come to an end.  This is my second year in transfer pricing as a transfer pricing officer in Mumbai. I have thoroughly enjoyed my tenure the first year has gone by and the second year has begun with some new experiments some new learning some new thoughts. Transfer pricing as a subject is quite technical but after having experienced it and practised it for one year I realised the fact that it is more of a common sense. Nevertheless there is no substitute for a thorough understanding of the subject as they say that knowledge is power and the knowledge of the subject brings a lot of...