Delhi High Court ruling on transfer pricing aspects of marketing intangibles

The Delhi High Court (HC), in a writ petition filed by Maruti Suzuki India Ltd. (Taxpayer) [WP.(C) No. 6876/2008] against the order of the Tax Authority, has ruled on transfer pricing (TP) aspects of marketing intangibles in respect of a licensing arrangement between the Taxpayer and its associated enterprise (AE), Suzuki Motor Corporation, Japan (Suzuki).

In its ruling, the HC, besides reiterating a number of key TP principles, has provided guidance on the circumstances under which a legal owner of a marketing intangible, suc

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