20 September 2013
Can anyone advice me if transfer pricing report is required in below mention case.
The assessee (Say Company A)has provided job work services to a sister concern(Say company B) worth more than 5 Cr.
No other transaction has taken place except this. The assessee claims that he was mere provider of service, and thus wont be covered under transfer pricing audit report. He claims that the sister concern (company B)would be covered under the same, since all the expenditure has been incurred by it.
21 September 2013
transfer pricing applies to both entities. The claim that A is just a service provider is wrong. The AO may like to determine whether income booked in A's books are at arm's length price or not.