India: Transfer pricing rules applicable to transactions between foreign company and its Indian branch (Tribunal decision)
Rules must be applied because foreign company taxable in India only on the income of its Indian branch
The Ahmedabad Bench of the Tribunal held that transfer pricing rules are applicable to transactions between a foreign company and its Indian branch because the foreign company is taxable in India only on the income of the branch.
The case is: TBEA Shenyang Transformer Group Co Ltd v. DCIT
Read a December 2024 report prepared by the KPMG member firm in India