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Instruction no. 3/2003 makes it mandatory for AO to make reference of an international transaction to TPO

August 16, 2019[2019] 108 taxmann.com 213 (SC)

TRANSFER PRICING : CBDT's Instruction No.3/2003 dated 20-5-2003 had mandated that wherever aggregate value of international transaction exceeds Rs. 5 crores, case should be pricked up for scrutiny and reference under section 92CA be made to TPO. If there are more than one transaction with an AE or there are transactions with more than one associated enterprises, aggregate value of which exceeds Rs. 5 crores, transactions should be referred to TPO

• By not making reference, Assessing Officer had breached mandatory instructions issued by CBDT, hence, matter was to be restored to file of Assessing Officer so that appropriate reference could be made to TPO.

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