Application for Advance Ruling - transfer pricing
This query is : Resolved
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 ?
15 February 2025
I feel it is better not to go for AAR. Just wait for the assessment to get completed. However if you feel that better not to get into litigation you may consider higher markup percentage.
You need to be the querist or approved CAclub expert to take part in this query .
Click here to login now
Click here to login now
Similar Resolved Queries
Unanswered Queries
- Due date for filing return for the partner in partnership subjected to Tax Audit
- Query on effect of registration of property
- GST on reimbursement of expenses
- Whether output tax is taken credit by purchaser
- Goodwill transfer of deceased father’s firm – ICAI applying a 27.04.2026 cut-off to the 3 year limit
- Additional trade name
- Equity Share Sale and Purchase
- Visiting card purchase
- Number of years as per AS amortisation of Goodwill
- Wrong CMPo8 file
- Classification of income of P Ltd company as business or profession
- Opting out" of regime provided under subsection (1A) of Section 115BAC but Form 10IEA is not filed.
- "Please ensure that the Total of the Deductions u/s 54F match the same in Table D in Sch CG"
- Need to correct "Whether it is last installment " response in Form 26 QB
- " Income from House Property " in joint names of co-owners
- REGARDING TDS RETURN OF FORM 27Q
- Notice under e-Verification Scheme
- GST demand notice for ITC reversal against exempted supply.
- RCM ON SECURITY CHARGES FROM INDIVIDUALS
- How to get money back from delisted company
Trending Online Classes
-
DT & Audit (Exam Oriented Fastrack Batch) - For May 26 Exams and onwards Full English
CA Bhanwar Borana & CA Shubham Keswani
Subscribe to Pro
Join an elite circle of professionals
CAclubindia
