Since 2001, when sections 92A to 92F were inserted for the first time in the Income-tax Act, 1961, there has been rapid evolvement of the field of Transfer Pricing. Application of the complex provisions of transfer pricing require determination of proper income arising from international transactions where either or both the parties involved happen to be non-resident(s).
Global existence of the multinational enterprises has augmented the number of cross border transactions with the associated enterprises. At the same time, the related law has also evolved and has posed various challenges for stakeholders.
The responsibility of examining the records and issuing the report under section 92E is on our members. Laws in respect of transfer pricing are complex but our members have been discharging their responsibilities ably. ICAI too guides its members in respect of the ever changing complex laws of Transfer Pricing. This Guidance note on Report under section 92E of the Income tax Act, 1961 provides guidance to the members in this regard.
The publication was last revised in the year 2016. However, in order to keep our members updated, the Committee on International Taxation of ICAI took up the task of revising the publication this year also. It is a pleasure to note that Committee on International Taxation of ICAI has brought out the sixth edition of “Guidance Note on report under section 92E of the Income-tax Act, 1961 (Transfer Pricing)” in a timely manner.
I compliment CA. Sanjiv K. Chaudhary, Chairman, Committee on International Taxation of ICAI and CA. N.C. Hegde, Vice-Chairman, Committee on International taxation for initiating and completing the task of revising this publication in a timely manner. The revised edition of the Guidance Note will surely be of immense use to the members as it will assist them in fulfilling their attest function in ably manner.
CA. Nilesh S. Vikamsey President ICAI
New Delhi Date : October 30, 2017
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