transfer pricing litigation in india -...

Transfer Pricing Litigation in India

April 27, 2013

Pune Branch of WIRC of ICAI

Direct Tax Refresher Course 2013

Pramod Joshi

Senior Director, Transfer Pricing

Trends in TP Audits in India- Increasing volumes

• Trends indicate greater scrutiny, leading to increased adjustments and resultant litigation

• Favorable decisions from Income Tax Appellate Tribunal

• Looking Ahead- Safe Harbour and Advance pricing agreement (APA)

• Approximately 9.3 Billion EUR addition on account of transfer pricing for FY 2008-09

Financial year No. of cases Cases adjustedCases adjusted (%)

Estimated addition (EUR)

2001-02 1081 238 22% 234 mn

© 2013 Deloitte Haskins & Sells

2002-03 1501 345 23% 439 mn

2003-04 1768 477 27% 658 mn

2004-05 1479 370 25% 844 mn

2005-06 1717 1019 59% 1661 mn

2006-07 2000 1040 (approx.) More than 50%3410 mn.

(approx)

2007-08 2589 1346 52%6829 mn.

(approx.)

Note-The above figures are estimations based on various presentations by the Department and news reports

2

Normal Dispute Resolution Mechanisms

Apex

Court

High Court

Tribunal

• Most tax disputes are dealt

under traditional dispute

resolution avenues

• 60 to 70 % of decisions by

Tribunal on transfer pricing

disputes in favor of the tax


Tribunal (final fact finding authority)

Commissioner (Appeals) / Dispute Resolution Panel

Tax

officer

disputes in favor of the tax

payer

• Each level of hierarchy involves

substantial period of time

3

Recent Key Transfer Pricing Assessment Issues

• Royalties for know-how and trademark/ trade names

• Intra-group services - management services fees / Cost contributions

• Guarantee fee, intercompany loans and other financial transactions

• Mark-ups for captive intra-group service providers, particularly ITES / BPO

industry

• Service companies and intangibles development in India


• Service companies and intangibles development in India

• Losses incurred

• Adjustments for functional differences

• Comparability of Domestic and Export Segment

• Comparable with higher profits/ losses

• Marketing intangibles (and the “access to market” argument)

• Valuation of Shares

4

Method Selection, Functional

Adjustments and its


Adjustments and its

Application

5

Schefenacker Motherson Ltd (SML)

Facts

� SML manufactures rear view mirrors and cable assemblies for the automobile industry

� International transactions include import of components, exports of cable assemblies and payment of

royalty for technical know-how

� TNMM with cash profit (CP) / sales as PLI used for benchmarking to eliminate differences in technology

used, age of assets, capacity utilisation and different depreciation policies adopted by comparables

� TPO rejected the above PLI stating that Rule 10B(1)(e)(iii) provides for adjustment to be made only to the

results of comparable companies and not to the tested party; and making a depreciation adjustment has no


sanction in law

Tribunal Decision / Observations

� Tribunal held that Cash Profit / sales or Cash Profit / total cost excluding depreciation can be adopted as an

appropriate PLI under TNMM, to adjust for material differences in the assets utilized between tested party

and comparable companies

� Discussed the concept of “Operating Income”. There is no standard test for deciding what constitutes

operational income (or profit) and that it would depend on the facts and circumstances of each case

6

Skoda Auto India Pvt Ltd (SAIPL)

Facts

� SAIPL is engaged in the business of manufacturing and selling passenger cars

� First full year of the operation for SAIPL

� International transactions include import of material and payment of royalties and technical

know-how fees

� SAIPL adopted TNMM as the most appropriate method and also relied on CUP method by

contending that ex-factory selling price by parent company would remain same for all AEs

� TPO rejected certain comparables on account of persistent losses and non-availability of


� TPO rejected certain comparables on account of persistent losses and non-availability of

contemporaneous data and made the TP adjustment

7

Skoda Auto India Pvt Ltd (SAIPL)

Pune Tribunal Decision / Observations

� CUP analysis rejected

� The transaction has to be between two entities which cannot influence or control each

other’s decision

� Tribunal observed that the business models of the comparable companies having an import

content ranging from 26 percent to 56.83 percent is fundamentally different from that of

SAIPL having import contents as high as 98.55 percent

� Adjustment would be required for unusually high costs on account of initial stages of


� Adjustment would be required for unusually high costs on account of initial stages of

business

8

Fiat India

Facts

� Taxpayer engaged in the business of manufacturing and selling of passenger cars and trading

of spare parts

� Taxpayer adopted TNMM and made comparability adjustments

� Under utilization of capacity

� Higher incidence of octroi and excise duty (due to slow moving stock)

� Low volume from otherwise profitable spare parts business


� Relatively higher employee salary costs due to underutilization

� TPO considered PBDIT as the PLI and made adjustment

Mumbai Tribunal’s Decision / Observations

� Taxpayer sufficiently explained and demonstrated material differences in the facts of the

taxpayer and comparable companies

� Taxpayer being in asset intensive industry depreciation should be considered on actual usage

of fixed assets for the purpose of computing the operating margin to lead to a meaningful

outcome

9

Cheminova

Facts

� Taxpayer engaged in manufacturing of agrochemicals, pesticides, weedicides and plant

growth stimulators

� Taxpayer purchased raw material from its AE and Non-AEs (Chinese suppliers)

� Purchased from domestic market at a higher rate than the price paid to AE

� Taxpayer selected CUP method



� Importance of economic and commercial factors in ALP determination

� Substitution to Chinese supplier was not feasible until quality was established

� Key takeaway – even in a case where adverse CUP exists, proper documentation of the

business reasons and robust economic analysis can come to the rescue

10

IL Jin Electronics

Facts

� Taxpayer was engaged in manufacture of Printed Circuit Boards

� Taxpayer imported 45.51% of the raw materials from its AEs

� TNMM was selected as the most appropriate method

� The TPO proposed an adjustment by rejecting certain high loss making comparables

� Taxpayer contended that working capital adjustments should be made to the margins of

comparable companies. Further, adjustment if any should be restricted having regard to

the proportion of the international transaction with total turnover.


the proportion of the international transaction with total turnover.

Delhi Tribunal’s Decision / Observations

� TNMM was selected as the most appropriate method in absence of data with regard topurchase of raw material by the AE from third parties

� Working capital adjustment depends on the credit period extended and availed by thetaxpayer

� The adjustment was restricted to the ratio of international transaction to the total cost ofraw material

11

Global Vantedge

Facts

� GV India is engaged in rendering IT-enabled services in the field of credit collection and telemarketingservices and is eligible for deduction under Section 10A

� GV India adopted TNMM as the most appropriate method considering AE as a tested party. GV Indiahad losses at operating level

� TPO considered GV India as tested party and made an adjustment to the international transactions bycomparing comparables’ margin of (-)11.88% with loss of GV India (-)53.5%


� Foreign entity could be selected as the tested party if it is least complex. However, due to non-


� Foreign entity could be selected as the tested party if it is least complex. However, due to non-availability of data for carrying out FAR / adjustments and geographical differences in entitlementsforeign entity could not be treated as tested party

� Total adjustment along with the ALP reported by the taxpayer cannot exceed total revenue earnedfrom the transaction from an end to end perspective

� Adjudicated that the taxpayer’s transactions with third parties should not be considered while usingTNMM

� It was held that comparables engaged in dissimilar activities and those having substantial relatedparty transactions should be rejected. Further, as the taxpayer was in the start-up phase, accordinglyadjustments due to surplus capacity should be carried out for the comparables.

12

Internal Comparability

© 2013 Deloitte Haskins & Sells13

Genisys Integrating System

Facts Ruling by Bangalore Tribunal

� The assessee was engaged in the

business of providing software

development and IT enable services

(Call Centres)

� Internal TNMM as the most appropriate

method for determining ALP of software

services

� The assessee provided similar

software development services to its

� Assessee had provided basis of

apportionment of direct and indirect cost


AEs and non-AEs and adopted

internal TNMM as the most

appropriate method to determine ALP

between AE and non AE and documentary

evidence and in absence of reasons to reject

TNMM, TPO to adopt internal TNMM after

verifying the cost allocation and margin

computation� The TPO rejected internal TNMM and

adopted external TNMM to determine

ALP resulting in adjustment to

software development services

� The DRP confirmed the adjustment

proposed by the TPO relating to

software development services

Drilbits International Private Limited

Facts Ruling by Pune ITAT

� The taxpayer was manufacturing bits forindustrial drill machines and were sellingto overseas parent as well as in India tothird parties

� On appeal the tax court deleted the adjustment bypointing out that comparison between domesticand export segment not tenable consideringmaterial differences in risks assumed andfunctions undertaken and no reasonableadjustment was possible to quantify

� The manufacturing units was earlierowned by another third party who wassupplying to the same overseas entity and

� The Tax court also asked the tax authorities tofollow rule of consistency as the approach of taxpayer (TNMM as a method) was accepted in


supplying to the same overseas entity andthe rates remained same even after theoverseas entity acquired themanufacturing unit through its Indian arm

payer (TNMM as a method) was accepted insubsequent year by the field officer

� The field TP officer rejected the CUP(price at which the earlier owner of factorywas selling the bits)

� The field TP officer used “cost plus” as amethod resorting to comparison betweendomestic and export segment and madeTP adjustment

Tecnimont ICB Facts

� The taxpayer Tecnimont ICB Private Limited, an Indian company was engaged in EPC turnkey contracts, design/

supervision/ translation services and feasibility studies

� Tecnimont ICB Private Limited had a 100% subsidiary in India ICB Contractors Private Limited

� Out of the total revenues of ICB Contractors Private Limited, 59% revenue was from one of the AEs (JTS)

� In the TP assessment, the assessee, contended that ICB Contractors Private Limited is a better comparable, after the TPOrejecting 12 external comparables

� TPO rejected on the ground of ICB Contractors Private Limited having related party transactions and made addition of Rs. 7crores

� CIT(A) deleted the addition

Ruling by Mumbai ITAT


� Accountant member of ITAT held that ICB Contractors Private Limited could not be a comparable as it is having relatedparty transactions

� Judicial member of ITAT took a view that since transactions between ICB Contractors Private Limited and JTS are at arm;slength, it could be considered as a comparable company

� The third member held that ICB Contractors Private Limited can not be taken as a comparable company as comparablecould be internal or external but in case comparable must be that of uncontrolled transaction or number of such transactions

� There is no statutory sanction for roping in a comparable controlled transaction for the purposes of benchmarking. When ithas been clearly mandated in all the relevant methods for determining ALP that the comparison has to be made by theenterprise's international transaction with comparable uncontrolled transaction, by no sheer logic a comparable controlledtransaction can be employed for the purposes of making comparison. There is no warrant for diluting the prescription givenby the statute or rules when such prescription itself serves the ends of justice properly and is infallible. If the view of theRevenue that a controlled transaction should not be shunted out for the purposes of benchmarking is accepted, then all the

relevant provisions contained in Chapter X in this regard, will become otiose.”

Turnover Filter, Functional

Comparability


Comparability

Trilogy E-Business Software India

Facts Ruling by Banaglore Tribunal

� Trilogy India was engaged in the

supply of software research and

development services to its U.S.

parent

� Trilogy India was remunerated at

cost plus 10 % and adopted TNMM

and while selecting comparable

companies used maximum turnover

� Turnover filter of Rs.1 crore to Rs.200 crore

may be applied in this case and export filter

is a must if the assessee renders services

to export market

� Onsite revenue filter may be used if the

assessee renders offshore software

development

� Comparables owning intangibles are


companies used maximum turnover

filter of INR 200 crores as its own

sales was INR 47 crores

� The TPO accepted the TNMM but

challenged selection of comparable

by rejecting maximum turnover filter

as well as didn’t exclude

comparables with abnormally high

margins

� The TPO revised the set of

comparables which resulted in high

margins

� Comparables owning intangibles are

functionally not comparable with the

assessee who does not own intangibles

� Abnormal profit making companies may be

excluded as comparables if supported by

sufficient evidence for such abnormal profit

� Comparables outsourcing majority of its

work to third parties may be excluded

Genisys Integrated Systems India Private Limited

Facts Ruling by Banaglore Tribunal

� Assessee was engaged in business

of software development and

rendering of ITES services to AEs

� TPO rejected turnover filter of the

assessee (1 to 200 crore rupees)

contending that Indian TP

regulations as well as OECD

guidelines did not prescribe turnover

� Considering size of business of the

assessee 1 to 200 crore turnover filter is

appropriate

� In this case ITAT also held in favor of the

TPO on issue of use of data which

becomes available after the due date of

filing the return of income (i.e. the date

generally by which companies undertake


guidelines did not prescribe turnover

filter and once the company is

functionally similar then it could be

compared irrespective of turnover,

size, scope of operations

� TPO applied several other filters and

rejected 10 comparables

generally by which companies undertake

the search and prepares the comparability

analysis as a part of transfer pricing

documentation)

Aggregation of Closely Linked

Transactions


Transactions

20

Demag Cranes & Components

Facts Ruling by Tax Court

� The taxpayer was providing state of theart material handling solutions to Indiancustomers

� On appeal the Pune tribunal noted that Indian TPregulations allows aggregation of closely linkedtransactions for determining arm’s length pricewhich is in line with OECD approach

� Taxpayer was basically having the projectbusiness consisting of:

� Manufacture of material handlingequipment

� While ruling out the TP adjustment, the tax courtobserved that the taxpayer enter into a singlecontract negotiation with customer formanufacturing and sale of cranes and hoistswhich includes manufacture, supply and services


� Purchase and distribution of importedmaterial handling equipment

� Availing of technical services andrendering of marketing services

which includes manufacture, supply and services

� The TPO applied TNMM by segregatingthe business into manufacturing,distribution and services segment andconsequently made TP adjustments

� For determining the need for aggregation oneneed to look at facts and circumstances of eachbusiness and cannot define parameters in a watertight compartment

RBI thresholds for ALP?

Mumbai ITAT’s 2 Opposite


Mumbai ITAT’s 2 Opposite

Rulings

RBI thresholds for ALP? Mumbai ITAT’s 2 opposite rulings

ThyssenKrupp Industries India Private Limited

SKOL Breweries Limited

� The assessee was engaged in business ofturnkey projects and paid 2% of contractvalue to its AE for know-how. It also paidroyalty of 5% of the selling price to the AEas per the collaboration agreement

� Assessee through Central bank of Indiaapplied to RBI for approval and RBI askedthe bank to consider assessee’s case in

� SKOL Breweries was engaged in manufacturingand marketing of beer in India and it was payingroyalty at the rate of 5% to SAB Miller for usingof technical know-how provided

� TPO rejected CUP and applied TNMM tobenchmark royalty with other transactions

� Mumbai ITAT ruled that RBI approval has no


the bank to consider assessee’s case inaccordance with AP (DIR Series) No. 76dated 24.02.2007 and under the deemedapproval given by RBI under automaticroute, ThyssenKrupp India made thepayment

� The TPO determined ALP at NIL proposingan adjustment of Rs. 4.29 crores

� Mumbai ITAT Held that when the rate ofroyalty payment and fee for drawings etc.has been approved or deemed to havebeen approved by the RBI, then suchpayment has to be considered at ALP

� Mumbai ITAT ruled that RBI approval has norelevance on issue of Arms Length Price andRBI, at the time of giving such permission wouldnot keep in mind the provisions of the I T Act andthat is the function of the income tax authorities

� When a proper mechanism is provided under theprovisions of the I. T. Act and Rules fordetermination of the ALP, then the approval byother than the I. T. Authorities, for the purpose ofremittance/outflow of the foreign exchange, doesnot ipso facto, partake the character of ALP,which has to be determined as per TPregulations

Inter-company Loans, Debt

and Guarantees


and Guarantees

24

Perot Systems

Facts

� The taxpayer was an Indian company engaged in the business of designing and developingtechnology enabled business transformation solutions

� The taxpayer had extended interest free foreign currency loans to its AEs

� The TPO adopted LIBOR + 1.64% as the arm’s length interest


Taxpayer’s Contentions before Delhi Tribunal

� The loans were in the nature of quasi-equity

� Hungary thin capitalization rules kicked in and part of the debt was treated as capital

� The AEs were start-up companies and no lender would have lent money

� The intention of advancing loan was to earn dividend and not to earn interest

� Real income concept argued

Perot Systems


� “No income arising” argument rejected

� Interest free loan does not satisfy the arm’s length principle

� No special feature in contract demonstrated to treat the loan transaction to be equity innature

� Contentions re commercial expediency / inability of the Sub to borrow - rejected


� Contentions re commercial expediency / inability of the Sub to borrow - rejected

Nimbus communication

Facts

� Taxpayer had receivables outstanding from AEs for > 180 days

� TPO attributed interest on extended credit and made adjustment

� For adjustment TPO used rate of interest charged for inter-company loan



� Taxpayer has not charged interest on delayed payments from third parties

� Taxpayer has not paid interest on delayed payments to its creditors

� TPO has not followed any of the methods in making adjustment

� Loans and trade credit are different and not comparable

� ITAT deleted adjustment on merits and law

Cotton Naturals (I) Private Limited

Facts

� The assessee was engaged in manufacture of apparel and had provided loan at 4% p.a. to

its AE

� Applying CUP the interest rate was comparable with export packing credit rate obtained from

independent banks in India

� TPO considering the domestic lending rate of 17.26% and made an adjustment and DRP

recomputed the adjustment by applying interest rate of 13.25%


Ruling by Delhi Tribunal

� Where transactions was of lending money in foreign currency to its foreign AE, the

comparable transaction would be foreign currency lending by unrelated parties

� Domestic prime lending rate would have no applicability and LIBOR should be taken as the

benchmark rate for international transaction relying on following ITAT judgments

� Siva Industries and Holdings Ltd (Chennai Tribunal)

� Four Soft Ltd (Hyderabad Tribunal)

� Tech Mahindra Ltd (Mumbai Tribunal)

� Tata Autocomp System (Mumbai Tribunal)

Intra Group Services –

Management Services Fees/


Management Services Fees/

Cost-recharges

Dresser Rand India Private Limited

Facts

� The assessee was a wholly owned subsidiary of Dresser Rand Co., USA engaged in the

business of manufacturing various types of process gas compressors

� The assessee paid towards cost contribution allocation (“CCA”) made by the parent

company owing to lack of facilities or manpower for various fields (such as legal, marketing,

technical , etc.)

� The TPO held that no ‘real service’ was availed and the expenditure was not genuine and

as such ALP is NIL


as such ALP is NIL

Ruling by Mumbai Tribunal

� revenue officers had no authority to question the assessee’ s commercial wisdom or decide

what was necessary, in order to conduct business effectively

� It can not be said that since the assessee had qualified staff on its roll, there was no need

for it to obtain services from AE

� it is wholly irrelevant as to whether the assessee benefits from it or not; the real question is

whether the price of this service is what an independent enterprise would have paid for the

same.”

� allocation of cost on the basis of head count and turnover was reasonable

Marketing Intangibles


Marketing Intangibles

� Within a multinational group, the trade mark owner is typically a separate entity, legally

and geographically, from the subsidiary that undertakes the marketing investment

� Typically, development of the market is at the risk and economic cost of the distributor

(or) the foreign parent indirectly subsidises the development of the market through a

reduced transfer price (or) the foreign parent provided the distributor with a rebate of a

portion of the distributor’s advertising & market promotion spend (AMP) based on sales

volumes

� High marketing expenditure by a subsidiary is increasingly being scrutinised by revenue


� High marketing expenditure by a subsidiary is increasingly being scrutinised by revenue

authorities – The authorities are either

a) Disallowing AMP expenditure of distributor

b) Deeming a service fee for the marketing effort

c) Expect higher marketing margins as return for investment

LG Electronics – ITAT Special Bench

Background

� LG Electronics Inc. (“LGK/AE”) is a Korean Company engaged in the manufacture, sale

and distribution of electronic products and electrical appliances

� LG Electronics India Pvt. Ltd. (“LG India/ assessee”) is wholly owned subsidiary of LGK

and has been engaged in manufacture and sale of LG brand goods

� LGK allowed LG India to use the LG brand name without any royalty


� Transfer pricing field officer observed that LG India incurred AMP expenses of 3.85% of

sales, which is more than the average AMP/ Sales ratio of two of comparables,

Videocon and Whirlpool (1.39%)

Questions

� Whether transfer pricing adjustment can be made in relation to AMP expenses incurred

by the taxpayer?

� Whether the taxpayer ought to have been compensated by the associated enterprises

(AE) in respect of such AMP expenses alleged to have been incurred for and on behalf

of the AE?

LG Electronics – ITAT Special Bench

Ruling in Brief – by majority of Judges

� There is a valid transaction in the form of excessive AMP expenses incurred by LG

India enhancing the LG brand, legally owned by LGK.

� Amount of the transaction is calculated by applying the bright line test, i.e. based on

level of AMP expenses of comparable companies LG India’s AMP cost were divided

between

• Those assisting local product sales


• Those assisting local product sales

• Those enhancing global brand value

� The amounts enhancing brand value should be paid by LGK along with a mark-up

Glaxo Smithkline Consumer Healthcare Limited

Facts Ruling by Chandigarh Tribunal

� The assessee engaged in

manufacturing and selling of

nutritional products under the

brands “Horlicks,” “Boost,” “Maltova”

and “Viva” in India

� Per TPO assessee had created a

marketing intangible by incurring a

� In view of the majority decision in LG

Electronics Special Bench case, incurring

of AMP expenses constitute an

international transaction

� Expenses incurred in connection with sales

such as discount on sales, market research

expenses, sales promotion expenses,


marketing intangible by incurring a

huge AMP expenditure on a brand

owned by an AE and thus, should

have been compensated at ALP by

AE

� The TPO added a mark-up of

13.04% to the “excessive” AMP

expenditure incurred by the

assessee after deducting the brand

development expenditure

expenses, sales promotion expenses,

selling and distribution expenses and

service charges paid to selling agents were

to be excluded from AMP expenses

� The ITAT directed the TPO to determine

ALP only in relation to AMP expenditure

incurred for promotion of only the foreign

brand and no adjustment is required to be

made in respect of the advertisement

expenses attributed to the promotion of

domestic brand owned by the assessee

Key Takeaways


Key Takeaways

� Detailed FAR analysis for tested party and comparable companies is crucial ; taxpayers must have a

robust documentation with sound FAR analysis and well developed economic analysis to justify the

transfer prices

� International transactions should not be aggregated unless they are inextricably linked

� Least complex entity to be selected as the tested party

� Adjustments be made to improve comparability

� Considering the factual nature of the transfer pricing disputes - the rulings have a limited precedent

value in case there are variation in facts


value in case there are variation in facts

Avoiding the Litigation:

Introduction of APAs


Introduction of APAs

38

Features of Indian APA Program

� Any person who has undertaken or is proposing to undertake an international transaction shall be

eligible to enter into an APA

� Unilateral, bilateral and multilateral APAs may be entered into – For bilateral and multilateral APAs

application to be filed with Indian Competent Authority

� APA team to include experts in economics, statistics, law or any other field

� Pre-filing consultation available including anonymous pre-filing route

� taxpayer may withdraw the application of APA at any time before the finalization of the terms of the APA

� The APA shall be entered into after its approval by the Indian Government


� The APA shall be entered into after its approval by the Indian Government

� APA shall not be binding on the Government or the taxpayer if there is a change in any of the critical

assumptions

� Taxpayer to file annual compliance return and tax authorities to carry out yearly compliance audit

� Revision of APA possible in case of change in critical assumptions/ law/ Request from competent

authority of other country in case of bilateral and multilateral agreements

� Renewal of the agreement is permissible

� No provision for roll-back as well as no formal firewalls between APA and tax authorities

The APA Process in India

Phase 1:APA PlanningPhase 1:APA Planning

Phase 2:Pre-filingPhase 2:Pre-filing

Phase 3:APA Submission

Phase 3:APA Submission

Phase 4:Post-Submission Process

Phase 4:Post-Submission Process

Phase 5: Drafting and Compliance

Phase 5: Drafting and Compliance

• APA strategy

• Fact gathering and analysis

• Economic

• Prepare pre-filing documents

• Pre-filing meetings with

• Prepare and file APA request /submission

• Acceptance

• Receive/Reply to tax authority questions

• Second, third round

• Finalize APA and sign agreements

• Adjustments and APA


• Economic analysis

meetings with tax authorities

• Acceptance letter

round questions

• Meetings with tax authorities

• Site visits

• Position Paper

• APA negotiations

and APA annual reports

• Annual Audit by tax authorities

Q & A


41


42

This material prepared by Deloitte Haskins & Sells (DHS) is intended to provide general information on a particular subject or subjects and are

not an exhaustive treatment of such subject(s).Further, the views and opinions expressed herein are the subjective views and opinions of DHS

based on such parameters and analyses which in its opinion are relevant to the subject.

Accordingly, the information in this materials is not intended to constitute accounting, tax, legal, investment, consulting, or other professional

advice or services. The information is not intended to be relied upon as the sole basis for any decision which may affect you or your business.

Before making any decision or taking any action that might affect your personal finances or business, you should consult a qualified professional

adviser . None of DHS, its member firms, or its and their respective affiliates shall be responsible for any loss whatsoever sustained by any

person who relies on this material.

This material is intended only for the use of the entity/person to whom it is addressed and the others authorized to receive it on their behalf. The

recipient is strictly prohibited from further circulation of this material.


transfer pricing litigation in india -...

Documents