Aztec Software case : a watershed in transfer pricing

In the Aztec Software case, a special bench was constituted to examine significant legal issues related to transfer pricing in India. This case examined the various Income Tax Act and OECD transfer pricing provisions, as well as the legal effect of Instruction 3 issued by the Central Board of Direct Taxes on transfer pricing matters, various methods for computing the arm's length price, their scope and evidentiary issues. The Income Tax Appellate Tribunal has sought to streamline Indian practice on transfer pricing to reflect that of international practice.