On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are specifically for the Indian taxpayer’s market and that benefit only the Indian taxpayer cannot be attributed to the foreign affiliate. The tribunal agreed with the taxpayer’s determination under the Comparable Uncontrolled Price (CUP) method.
India: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE
June 20, 2018
Share This
