India Tax Tribunal challenges transfer pricing study assumptions
February 06, 2008
Hardev Singh and Saurabh Dhanuka, of TP Week correspondent KPMG, report on the tribunal’s analysis of transfer pricing approaches
In a major ruling involving a multinational pharmaceutical company, the Indian Tax Tribunal has rejected the findings of the business’ transfer pricing study. The tribunal has endorsed the re-opening of a closed transfer pricing audit by the Administrative Commissioner of Income Tax. What gives this ruling greater impact are its observations on the transfer pricing analysis conducted by the taxpayer.
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