Notified Jurisdictional Area (NJA) under Section 94A:
ANo effect
BExempts from TP
CHigher concessional rate (per relevant Section) (per relevant Section)
DDeems all parties in such area as AEs (per relevant Section)
Answer & Solution
Correct answer: D. Deems all parties in such area as AEs (per relevant Section)
1. Section 94A: Central Government can notify country/territory as NJA where inadequate info exchange.
2. All transactions with NJA-residents deemed TP transactions; TDS at higher rate (30% or rate in force).
3. No deduction without TP documentation compliance.
_Source: ICAI BoS CA Final Paper 7, Ch 24 "Transfer Pricing"_
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