Landmark rulings shape transfer pricing policy.

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    • Abstract:
      The article discusses relevant issues concerning landmark rulings related to transfer pricing law in the Indian Income Tax Act of 1961. Associated with these issues are the outsourcing costs and the level of certainty provided to corporate boards, flow of consideration for services from the overseas jurisdiction and the service provider. An annotation and factual analysis of the stewardship activity in connection wit the judgments passed by the judiciary in India in the case of Morgan Stanley & Co. and the Special Bench of the Income Tax Appellate Tribunal in the case of Aztec Software and Technology are presented.