Instruction No. 10 of 2013 has been issued by the Central Board of Direct Taxes (“CBDT”) on 5th August 2013 which specifying the procedures and criteria for manual selection of cases by the tax administration for audit/ scrutiny for financial year 2013-14.
This instruction No. 10 of 2013 provides for compulsory transfer pricing audit in two situations which are as follows:
– Where the value of international transaction with associate enterprises exceeds INR 15 crores (approx USD 2.46 million); and
– Where transfer pricing adjustments in excess of INR 10 crores (approx USD 1.64 Million) or more were made in the earlier assessment year and such adjustments are confirmed in an appeal or are pending before appellate authority.
