In the case of: DCIT v. W.B. Engineers International Pvt. Ltd. (ITA No. 523/PN/2014, The Pune Bench of the Income-tax Appellate Tribunal upheld the findings of the Dispute Resolution Panel that because a taxpayer merely hold substantial single-party purchases, this factor alone did not prove an influence on pricing or other conditions that would be present in an associated enterprise or related-party relationship under the transfer pricing rules.

In that case, the taxpayer countered that it was only a distributor, and not a related party or associated enterprise of the foreign group. Also, the taxpayer point out that there were other distributors of this group in India, as well.  The tribunal also detected that the clauses of the distribution agreement showed that both the taxpayer and the supplier were independent parties. As such, the transfer pricing provisions were not applicable to the taxpayer.

Finally, the Dispute Resolution Panel agreed with the taxpayer, that this was not a related-party relationship and that the transfer pricing rules did not apply.