Analysis of Transfer Pricing Judgements


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By CA Narendra Jain



Transfer pricing compliance today features as a high priority item for every multi-national enterprise and tax administration.  In 2014 itself, Indian judicial records was enriched with around 400+ reported decisions!! India has become leading contributory in the development of global transfer pricing law.  Indian Courts have rendered many thought provoking decisions. However the absence of consistency has only resulted in conflicting or divergent views on most of the issues before them.  The application of transfer pricing provisions is intricate and vague like never before. The book comprises of more than 700 India Transfer Pricing decisions covering various issues.


This is the second and updated edition of the book Compilation of Transfer Pricing Judgment, now renamed as Analysis of Transfer Pricing Judgments. .  The book is not a mere sequel but an attempt to collate and capture the essence of Indian transfer pricing judgments providing an insight into the multi directional evolution of the transfer pricing law. Comprehensive analysis has been made of all important decision related to an issue giving insight into divergent views of the Courts.  Comprehensive index tables have been prepared for easy reference. 

 Key features

  • Analysis of more than 700 Indian Transfer Pricing decisions
  • Coverage of multitude of topics along with analysis of amendments, such as

    • Applicability and legal issues
    • Methods and ALP Computation
    • Filters and Adjustments
    • Profit Level Indicator,
    • Penalties etc,
  • Issue-wise discussion of the decisions, each giving insight into different views of the Courts
  • Coverage of Key Industries
  • User-friendly layout and an index to locate cases by topic, industry and ‘in favour of’ 

 USP of the Book

  • Coverage of various topicslike Legal Issues, Associated Enterprises, International Transactions, Application of Methods, Computation of ALP, Adjustments, PLI and Penalties etc
  • Various issues under each topic were identified and decisions analysing those issues including contrary view were summarised at one place
  • Comparables related to certain industry segments are also analysed in detail based on decided case laws
  • Important Judicial and Legislative developments in the field of transfer pricing have been analysed and summarised under relevant topics.
  • Comprehensive index tables as per Topic, Industry and ‘In Favour of’ have been prepared for easy reference.