Indian tribunal scolds transfer pricing officers
February 25, 2010
The Mumbai Income Tax Appellate Tribunal has ruled that when determining the arm’s-length price of an international transaction, transfer pricing officers (TPO) must apply transfer pricing methods in accordance with the manner in which they are prescribed in the country’s transfer pricing rules.
In the case of CA Computer Associates v DCIT, the taxpayer was primarily engaged in the business of licensing mainframe midrange and system infrastructure software products of its US parent company, CA Management.
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