Foreign comparable could be chosen for foreign companies rendering services to Indian AE

Tata Motors European Technical Centre Plc vs.Dy CIT [2016] Mumbai Tribunal

The issue that was disputed in the instant case was as under-

‘Whether foreign company rendering services to its Indian AE could be compared with a foreign entity’

It was held by the Tribunal that where a British company, having its PE in India, rendered design and engineering services to Indian AE, foreign comparables i.e. UK based comparables would be taken into consideration while determining ALP of services so rendered.

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