On selection of Income Tax assessee's Foreign Associated Enterprise as "Tested Party" in Transfer Pricing analysis: What Madras High Court ruled

The judgment was pronounced last week by a Bench of Justices TS Sivagnanam and RN Manjula.
Madras High Court, Principal Bench
Madras High Court, Principal Bench

The Madras High Court recently clarified that in determining transfer pricing, to ascertain the net profit margin realised by an enterprise from international transactions, the tested party selected can also be a foreign associated enterprise of the income tax assessee, by applying the least complex theory (M/s Virtusa Consulting Services Private Limited v DCIT, Chennai).

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