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Bangalore Tribunal overturns official’s action

September 30, 2008

The Bangalore Tax Tribunal has ruled in favour of the taxpayer in a dispute that covered the powers of a transfer pricing officer to disregard a company’s transfer pricing analysis.

The order related to Philips Software Centre, a captive software development company, and dealt with issues including the trigger point for a transfer pricing audit, the use of contemporaneous data by a specified date, rejection of related-party transactions, quantification of risk and working capital adjustments and confirmation of safe harbour provisions.




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