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Office of The Comptroller and Auditor General of India

10, Bahadur Shah Zafar Marg, New Delhi

DY/ITRA/C&AG/235

Dated 29/03/2016

To

1.    The Director General of Audit (Central Receipts), New Delhi

2.    The Director General of Audit, Central, Kolkata

3.    Principal Director of Audit, Central, Ahmedabad, Bengaluru, Chandigarh, Chennai, Hyderabad, Lucknow and Mumbai

Subject : Floor limits of tax effect for individual draft paragraphs relating to transfer pricing

Sir/Madam,

Please refer to this office letter no. 560/RA(DT)/122-3008/Coordn/ dated 18 May 2012 regarding floor limits of tax effect of individual draft paragraphs.

2.    We have included a separate Chapter relating to Transfer Pricing in the Compliance Audit Report for the year 2014-15 (No. 3 of 2016). We expect that every year substantial number of Transfer Pricing cases would be processed. Since Audit points out short/excess adjustment done by Transfer Pricing Officers, it has, therefore, been decided to fix the following limits of short/excess adjustment by TPO for Compliance Audit Report 2015-16 and onwards :

TP cases Category ‘A’ States Category ‘B’ States
Corporate assessee ₹ 2 crore ₹ 1 crore
Non-corporate assesse ₹ 1 crore ₹ 50 lakh

3. It is therefore requested to send all TP cases in the above limits. It is also requested that all TP cases alongwith complete key documents may also be uploaded through OMNIDOCS systems only.

Yours faithfully,

(R.B. Sinha)

Director General (Direct Taxes)

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