Issue of shares – The after effects of Vodafone & Shell rulings

Issue of equity shares to a non-resident Associated Enterprise (AE) has been a hot topic for transfer pricing adjustments in the last couple of years. The Bombay High Court finally settled

Sep 08, 2015

Marketing Intangibles - Analyzing litigation trends post Delhi HC verdict

A growing number of multinational enterprises (MNEs) have been tapping the Indian market by offering their products through local affiliates. Due to strong market competition, they have substantially increased their

Jul 20, 2015

Taxand global survey highlights MNCs 'reputation' concerns, increasing TP scrutiny , CbC split

Taxand’s Annual Global Survey captures the mood of companies (across Americas, Europe and Asia) adapting to changing global tax environment, 2/3 respondents say tax issues form part of board level

Mar 13, 2015

The 74 judgments on "turnover filer" that were presented before Bangalore Tribunal!

Turnover filter has been a persistent point of dispute, especially in the IT-ITeS sector, for purposes of selection of comparable companies to benchmark international transactions. Rule 10B(2) of the Income-tax

Feb 26, 2015

Judicial trends on guarantee issue - A debate far from over

Extending guarantee on behalf of subsidiaries and other related entities, for enabling them to obtain finance, is a very common phenomenon for MNCs.    However, these guarantee transactions of MNCs have

Mar 14, 2014

Judicial Trends on Acceptance/ Rejection of 100+ IT / ITeS comparables

Information technology (IT) and Information Technology Enabled Services (ITeS) industry has witnessed considerable Transfer Pricing litigation. Among various areas of disputes, selection of comparable companies has been a matter of

Oct 24, 2013