Transfer Pricing 360º – November 2018

Transfer pricing litigation environment in India has been evolving over a period of time. In recent past, Indian courts have provided judgment on complex Transfer Pricing related issues involving of Intangible related transactions. At the same time, it continues to provide useful guidance on fundamentals of transfer pricing laws in India. In this issue, we have covered one of the recent Tax Tribunal judgment on application of Comparable Uncontrolled Price Method considering the data / quotations published on Internet / stock exchange. The ruling suggest that only a reliable and authentic quotations having similar physical features of products, contractual terms, similar timing/ terms of delivery, etc can be considered as a valid comparable uncontrolled price. The key take away from this ruling is that, multinational companies are advised to give robust attention during the stages of transfer pricing documentation preparation in order to factor all such important