A recent survey of Indian transfer pricing cases reveals that while the country's international tax appellate tribunals are beginning to touch on substantive transfer pricing issues, such as the treatment of marketing intangibles and loan guarantees, many of the ITAT opinions continue to focus on procedural issues and fail to create substantive law. In Four Soft Private Pvt. Ltd. v. Deputy Comr. of Income Tax, decided by the Hyderabad ITAT, the tribunal rejected the transfer pricing officer's adjustment for the taxpayer's loan guarantee made to a bank for a related entity. The court adopted the taxpayer's view that the corporate guarantee for a bank loan it provided to an entity in the same corporate group did not fit within the definition of "international transaction" set forth in Section 92(B)(1) of the Income Tax Act… Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library. Already a subscriber? Sign in here Disclaimer
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