Indian tribunal rules on differences in comparability analysis
April 01, 2009
An Indian tax tribunal has said a taxpayer may have to change costs and profits on account of differences which arise in comparability analysis, but still referred the case back to a transfer pricing officer
The decision by the Pune Bench of the Income Tax Appellate Tribunal was in a case where Skoda Auto India Private Limited, a car maker, decided to benchmark its international transactions using the transactional net margin method. The transactions concerned the purchase of raw materials and payment of royalties and for technical know-how.
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