AAR held that ; No requirement that transaction should result in income chargeable to tax for transfer pricing provisions to get attracted .Transaction of sale of shares in Indian company to be bench marked under transfer pricing provisions.
“AB” Mauritius, In re (2018) 402 ITR 311/ 163 DTR 170 (AAR)
S. 92: Transfer pricing -International transactions — Arm’s length price — Transaction of sale of shares in Indian company to be benchmarked under transfer pricing provisions. [S. 92A to 92F ]