AMIT BAJAJ ADVOCATE

With the advent of MNCs(Multi National Concerns) a trend has also been adopted by the MNCs to structure their investments and business strategy in such a way that profits are maximized in such jurisdictions where tax rates are low, which give rise to the emerging  problem of transfer pricing all over the world. Many countries have made laws to deal with the issue of transfer pricing. India has been a late enterant in making provisions under the Income Tax Act to tackle the issue of transfer pricing. Although there existed section 92 under Income tax Act 1961 but there were not relevant rules which could help tackle the issue of transfer pricing. Section 92A to 92F had been inserted to deal with transfer pricing by the Finance Act, 2001. Some views are expressed in this article as below explaining provisions under the Income Tax Act 1961 dealing with transfer pricing.