Indian Revenue opportunism rules out multiple year data
August 17, 2011
The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ from global best practice.
Issues of particular contention in the case relate to the use of comparable data not being available to the taxpayer at the time of preparing documentation. Further, the case shows that Indian courts continue to reject the use of multiple year data for preparing transfer pricing documentation.
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.