AZ (India) Ltd (an Indian Company) is a wholly owned subsidiary of AZ Inc. USA. AZ Inc. USA is incorporated in USA and tax resident of USA. During…
CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
AZ (India) Ltd (an Indian Company) is a wholly owned subsidiary of AZ Inc. USA. AZ Inc. USA is incorporated in USA and tax resident of USA. During the Financial Year 2024-25, AZ (India) Ltd imported Electronic Devices manufactured by AZ Inc. USA for sale to unrelated customers in India. AZ (India) Ltd has not made any value addition before the sale of the devices imported from AZ Inc. USA and has also not incurred any marketing or brand promotion expenses for or on behalf of AZ Inc. USA. In such a situation, which of the following statement is correct :-
Suggested Answer and Working Notes:
Correct Answer: Option (C)
The Most appropriated method for determination of the arm's length price in respect of Electronic Devices imported by AZ (India) Ltd shall be Resale Price Method.
Topics: Transfer Pricing, Double Taxation Relief, Non-Resident Taxation
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