Proposal on Determination of the Arm’s Length Price Using the Range Concept

While presenting the Union Budget 2014-15, the Finance Minister proposed the introduction of the concepts of “range” and “multiple-year data” in Indian transfer pricing, with the objective of reducing transfer pricing litigation in India. The Central Board of Direct Taxes has developed a draft scheme, which contains detailed provisions as regards the application of “range concept” and the use of “multiple year data” for transactions undertaken for financial years 2014-15 and onwards.