https://www.taxtmi.com/caselaws?id=334990 The Tribunal dismissed the appeals, confirming the arm's length price adjustments made by the tax authorities. It held that the base erosion argument was not acceptable and that treaty protection under Article 9 of the Indo-Dutch tax treaty does not prevent the application of domestic transfer pricing regulations. The Tribunal emphasized the mandatory nature of the arm's length principle under Section 92(1) and rejected the arguments on both base erosion and treaty protection grounds. The judgment highlights the significance of applying transfer pricing regulations to prevent tax base erosion and ensure international transactions are conducted at arm's length prices. en-us Thu, 17 Nov 2016 00:00:00 +0530 Thu, 24 Nov 2016 20:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334990 The Tribunal dismissed the appeals, confirming the arm's length price adjustments made by the tax authorities. It held that the base erosion argument was not acceptable and that treaty protection under Article 9 of the Indo-Dutch tax treaty does not prevent the application of domestic transfer pricing regulations. The Tribunal emphasized the mandatory nature of the arm's length principle under Section 92(1) and rejected the arguments on both base erosion and treaty protection grounds. The judgment highlights the significance of applying transfer pricing regulations to prevent tax base erosion and ensure international transactions are conducted at arm's length prices. Case-Laws Income Tax Thu, 17 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334990