sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing | GST - Goods and Services Tax
Latest Expert Exchange
« Transfer Pricing »
 Private Company, New Delhi
 Motilal Nehru National Institute Of Technology, Allahabad, Uttar Pradesh
 I-T tribunal sends back Microsoft transfer pricing case to tax officer
 Transfer Pricing Adjustment - Status and Way Forward
 Transfer Pricing in India Explained
  Doing business in India: ‘Substance’ over ‘form’ in transfer pricing regime
 Tax authorities focus on transfer pricing adjustments
 Transfer Pricing: The AMP Issue Keep Oscillating
 Transfer pricing-A reputational risk?-Moore Stephens
 Department Of Consumer Affairs, Ahmedabad, Gujarat
 Polish transfer pricing guidance would alter low-value transactions, loans, documentation

Indian Tribunal rejects transfer price adjustment in Microsoft case
January, 07th 2015

The Delhi Income Tax Appellate Tribunal (Tribunal) rejected an approximate INR 290 million (about $4.5 million) transfer pricing adjustment relating to marketing services provided by the assessee, Microsoft Corporation India Pvt. Ltd., to its US parent and Singapore and UK affiliates. The dispute centered on determining the appropriate comparables to include in determining an arm’s-length operating margin. The assessee computed an arm’s-length operating margin of 7.32% based on nine comparables. The transfer pricing officer computed an arm’s-length operating margin of 21.18% after including five additional comparables, which not only engaged in routine marketing services but also provided high-end marketing services leading to the creation of marketing intangibles, and making other adjustments.

The transfer pricing officer argued that these five companies had been used as comparables by the assessee in the past. The Tribunal agreed with the assessee that the five companies did not provide comparable marketing services and that the inclusion by the assessee in prior years was not determinative.

Home | About Us | Terms and Conditions | Contact Us
Copyright 2018 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Sitemap

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions