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Associated Enterprise – The Heart Of International Taxation And Transfer Pricing

Abhirami Retheev, SLS Pune


Transfer pricing is the setting of the price for goods and services sold between controlled or related entities within an enterprise.1 Section 92A to 92F of the Income Tax Act, 1961 deals with transfer pricing. Income arising from international transaction, i.e., a transaction between two or more associated enterprises, either or both of whom are non-residents, is a pre-condition for the application of these provisions.2 Thus, it is necessary to clearly identify “associated enterprises” in international transactions. This article discusses the concept of associated enterprise under section 92A, the interplay between clauses (1) and (2) with supporting case laws and illustrations.

Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878


Accessibility: Open Access

License: Creative Commons 4.0

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​All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.


The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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