The Delhi bench of the Income-tax Appellate Tribunal in the case of Sona Okegawa Precision Forging Ltd (2010-TII-41-ITAT-DEL-TP), has examined the issue of duplicative services and whether royalty can be paid to the associated enterprise (AE) for sales made to the AE itself.
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals