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Indian Court Holds Structure of a Transaction may be Disregarded if Not Commercially Rational

|Approved Changes|India
India

The High Court of Delhi recently ruled on whether the structure of a transaction may be disregarded for transfer pricing purposes on the basis of not being commercially rational. The case involved two related appeals by Denso India Ltd. (Denso), a company engaged in the manufacture and sale automotive electronic products.

For the assessment years 2002-03 and 2003-04, Denso used the transaction…

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