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Issue/Justification

The existing provisions under Section 92BA of the Income-tax Act, 1961, require an assesse to comply with the transfer pricing provisions if the aggregate of the Specified Domestic Transactions (SDT) exceeds INR 20 crore during an assessment year.

A small assesse is required to comply with the transfer pricing provisions, leading to increase in the compliance burden and cost.

Suggestion

It is therefore recommended that, the threshold limit of INR 20 crores needs to be revised upwards, preferably up to INR 50 crores providing relief to the small assesse. The above proposed amendment will also provide a boost to the ease of doing business initiative of the government, as it will reduce compliance burden and cost of the assessee.

Source-  ICAI Pre-Budget Memorandum–2018 (Direct Taxes and International Tax)

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