India - Applicability of Transfer Pricing Provisions to the Assignment of Contracts
- P. Raj Kumar Jhabakh
- International Transfer Pricing Journal, 2014 (Volume 21), No 2
- 10 March 2014
In the recent ruling in Tellabs India Private Ltd v. The Assistant Commissioner of Income Tax, the Income Tax Appellate Tribunal, Bangalore held that transfer pricing provisions are applicable to the assignment of contracts among associated enterprises. This article analyses the judgment of the Tribunal and its impact on transactions involving associated enterprises, as well as their role in the negotiation of such transactions.