Q. Applicability of Transfer Pricing Provisions on Payment collected by Foreign Wholly Owned Subsidiary

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Question added Jun 15, 2023 Transfer Pricing By Ankit Mittal, CA, Delhi
ABC Limited has wholly owned subsidiary DEF Private Limited incorporated in Nepal. ABC Limited provides services to clients in Nepal and the proceeds of such services  is collected by DEF Private Limited from clients in Nepal in its bank account in Nepal

Then DEF transfers the proceeds to ABC Limited's bank account in India. Is transfer pricing applicable as in my opinion the transaction does not impact Profit or Loss or Assets of any Associated Enterprise.

Please Guide

Concept by CA Pramod Jain

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