Transfer Pricing Comparables – Insight into IT & ITeS

Taxsutra is glad to present 1200+ pages book titled Transfer Pricing Comparables – Insight into IT & ITeS, published by LexisNexis. Indian Transfer Pricing (TP) law is amongst the most litigated TP laws in the world. One of the major areas of TP disputes relates to selection of ‘suitable’ comparable entities and determination of margins, to arrive at arm’s length price (ALP).


This Book aims to track a specific area of tax dispute on comparables for IT and ITeS sector. Taxsutra’s experienced editorial team, based on review of judicial rulings, discussion with various professionals from across the country and feedback from Revenue officers, has handpicked 80 companies IT & ITeS sector in this first edition of the book.


The Book has been blessed by foreword from Dr. Parthasarathi Shome, Chairman of Tax Administration Reform Commission, Government of India and Mr B. M .Singh, Former Chairman, Central Board of Direct Taxes.  


Dr. Shome notes that the comparability analysis will continue to be directly relevant for appropriate transfer pricing analysis, even after legislative changes relating to introduction of range concept and safe harbour rules. He further comments, This 1000+ pages book provides excellent insight on companies in the Information Technology sector vis-a-vis its transfer pricing comparability. The book has presented information in a structured format which makes it useful for readers to get a quick understanding of the business on the basis of Functions-Assets-Risk (FAR) analysis.  He believes that The huge amount of data, information and subjective analysis also provide a basis and direction on how the transfer pricing law might be further simplified in a way that Government resources are not compromised and yet the business finds it easier to operate in India. Dr Shome also writes that the book would be relevant not only to the professionals, but also to the Revenue and Judges of the appellate forums and Courts.


In the foreword, Mr. B.M. Singh has mentioned that …this publication fits in with the needs of both the tax representatives and the Departmental officers including the appellate authorities. All concerned professionals will be well served in having a copy on their book shelves. This contains a wealth of information of 80 IT and ITeS companies regarding their financials up to 2012-13 on the basis of which FAR analysis can be undertaken and their suitability for comparison ascertained. Each company’s involvement in litigation as a comparable company has also been detailed.

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