Indian Tax Tribunal Holds Equity Investment Cannot be Subject to Transfer Pricing Rules

The Income Tax Appellate Tribunal in Mumbai recently issued its decision on whether a company's equity investment into a subsidiary can be subject to transfer pricing rules and recharacterized as a loan.
The case involved an Indian taxpayer that was part of an affiliated group of an Indian security services provider. During the 2008-09 tax year, the taxpayer acted as the investor for the acqu…
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