Indian Appellate Tribunal Holds Taxpayer's Acceptance of Tax Authorities Transfer Pricing Position in Earlier Year does Not Equate to Consent in Later Years

In a recently published ruling from the Delhi Income Tax Appellate Tribunal, the Tribunal ruled on whether a taxpayer's acceptance of a set of comparables as part of an earlier mutual agreement procedure (MAP) can be used against the taxpayer in subsequent years.

The case involved Turner International India Pvt. Ltd (TII), which distributes satellite channels in India. In the 2005-06 and 2006-07 tax years, TII had related party transactions related to subscriptions fees, marketing, distribu…