Sony comes out on top in safe harbour ruling
September 25, 2008
KR Girish and Hardev Singh of www.tpweek.com correspondents, KPMG, reveal why the Delhi Tax Tribunal sided with the taxpayer in a critical dispute over India’s safe harbour provisions
In a landmark judgment, the Delhi Tax Tribunal in the case of Sony India (P) Limited (Sony India) has confirmed the availability of India’s safe harbour provisions to be at the option of the taxpayer, with risk adjustment in respect of market risk, R&D risks and acceptability of comparables, with controlled transactions.
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