Transfer Pricing- Applicability of Arm’s Length Standard to Marketing of Intangibles

Delhi High Court Ruling: Transfer Pricing – Sec 92 – An important ruling by the Hon’ble High Court wherein it has been held that the methodology to be adopted by the Revenue Authorities for making an adjustment should be equitable and fair, and has ruled on the payment for the use of intangible assets and attributing arm’s length consideration for activities carried out by the licensee, etc. [Maruti Suzuki India Limited – W.P. 6876/2008] Facts: Maruti Suzuki India Limited (‘Petitioner / Maruti’) is engaged in manufacture and sale of automobiles. Maruti is also engaged in trad...