Application for Advance Ruling - transfer pricing
This query is : Open
23 January 2025
Hello everyone,
A ltd is 100% subsidiary of a german company incorporated in the year 2022-23 (captive unit) to provide IT services to its parent/group companies from India.
they are billing @ cost+13%. However consultant has opined that industry margin is 18-20%.
My question
1. Is it advisable to file application before AAR ?
2. I am worried that if order is unfavourable then AO may make primary adjustments for 22-23 and 23-24 as well even though we have TP report from reputed auditor ?
A ltd is 100% subsidiary of a german company incorporated in the year 2022-23 (captive unit) to provide IT services to its parent/group companies from India.
they are billing @ cost+13%. However consultant has opined that industry margin is 18-20%.
My question
1. Is it advisable to file application before AAR ?
2. I am worried that if order is unfavourable then AO may make primary adjustments for 22-23 and 23-24 as well even though we have TP report from reputed auditor ?
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