Indian decision on selection of appropriate comparables to determine arm's length price

The Indian Income Tax Appellate Tribunal (ITAT), delivered a ruling dated 2 November 2007 in the case of Mentor Graphics v. Deputy Commissioner of Income Tax (unreported) on some basic and fundamental aspects of the transfer pricing legislation in India.
(a) Facts. The Taxpayer (i.e. Mentor Graphics) was a wholly owned subsidiary of a US entity, and it was engaged …
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