Rs.5 Cr limit for Domestic TP applies on aggregate basis: ICAI Guidance

Apr 23,2013

“Specified Domestic Transactions (SDT)” threshold of Rs. 5 Cr to apply for all types of transactions together & not ‘per limb’, states ICAI’s revised Guidance Note; Transactions with a foreign entity having say 23% equity stake could qualify under Domestic TP; Guidance Note provides illustration on applicability of 6th method of determination of ALP; No guidance yet on whether step-down subsidiary covered under domestic TP.

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