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Foreign enterprises electrónico eligible as a tested party? P. Raj Kumar Jhabakh and Varsha Balasubramanian

By: Jhabakh, P. Raj Kumar.
Contributor(s): Balasubramanian, Varsha.
Material type: ArticleArticlePublisher: 2021Subject(s): PRECIOS DE TRANSFERENCIA | GRUPOS DE EMPRESAS | SOCIEDADES EXTRANJERAS | INDIA In: International Transfer Pricing Journal v. 28, n. 4, 2021, p. 288-290Summary: This article provides an analysis of the recent ruling of the Madras High Court in the case of Virtusa Consulting Services Private Limited v. DCIT, Chennai. The Madras High Court has through this order expanded the scope of who is a "tested party" for the determination of arm's length prices in controlled transactions. The High Court held that a foreign associated enterprise can be a tested party for the purpose of determining the arm's length price.
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Disponible únicamente en formato electrónico.

Resumen.

This article provides an analysis of the recent ruling of the Madras High Court in the case of Virtusa Consulting Services Private Limited v. DCIT, Chennai. The Madras High Court has through this order expanded the scope of who is a "tested party" for the determination of arm's length prices in controlled transactions. The High Court held that a foreign associated enterprise can be a tested party for the purpose of determining the arm's length price.

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