India High Court Holds Transfer Pricing Framework in MAP Agreement Cannot be Extended to Other Transactions
The Delhi High Court (HC) issued a judgment on 6 February 2025 concerning whether the transfer pricing framework agreed to under the mutual agreement procedure (MAP) of a tax treaty may be extended to similar transactions not covered by the MAP agreement. The case involved an Indian company that was engaged in transactions with related parties in the U.S. and certain other countries. The trans…
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