Transfer Pricing Adjustment on Issuance of Shares to Overseas Parents Leaves Companies Shell-Shocked

Journal
India
International Transfer Pricing Journal 2013 (Volume 20), No. 5
The author considers the latest transfer pricing controversy to originate from India, namely the attempt by the tax authorities to tax the discount on shares issued to a foreign parent company, as well as the assertions made by taxpayers and the tax authorities to defend their positions.