The Bombay High Court delivered a ruling dated 13 February 2007 in the case of SGS India (P) Ltd v. Assistant Commissioner of Income Tax (208 CTR 263) on whether the tax authorities can dispute and re-open an earlier year's completed tax assessment based on adjustments made in the tax assessment of a subsequent year to arm's length price of certain international transactions pursuant to the transfer pricing regulations.
(a) Facts. The Taxpayer (i.e. SG…