Indian decision on applicability of tax exemption on income arising from transfer pricing self-adjustments

The Bangalore Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 27 November 2007 in the case of I Gate Global Solutions Limited v. Assistant Commissioner of Income Tax, Bangalore (112 TTJ 1002), on whether a taxpayer who had entered into a cross-border transaction with an associated enterprise, was entitled to deduct from its taxable income, the difference between the book price of the transaction and the higher arm's-length price (ALP) as determined under India's tra…