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India: Tribunal decisions on transfer pricing issues

India: Tribunal decisions on transfer pricing issues

The Kolkata Bench of the Income Tax Appellate Tribunal issued decisions on certain transfer pricing issues.


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The case is: Philips Medical Systems (P.) Ltd. V. ITO

  • The tribunal ruled in favour of the taxpayer by holding that an entity engaged in both manufacturing as well as trading activity, in the absence of segmental accounts, cannot be treated as a comparable company for benchmarking the taxpayer (engaged mainly in trading activity).
  • The tribunal rejected the taxpayer’s position that comparables whose results are not available in the public domain should not be considered. The tribunal upheld the order of the Commissioner of Income-tax (Appeals).

Read a March 2019 report [PDF 561 KB] prepared by the KPMG member firm in India

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