The Punjab & Haryana High Court has ruled against Coca-Cola India’s contention that the proof of profit transfer outside India is a precondition for applying transfer pricing rules.
Coca-Cola had approached the high court after it was served a notice on transfer pricing.
The soft drink company had an agreement to offer advisory services to Britco at the rate of cost plus 5%.
Coca-Cola’s main contention was that transfer pricing rules cannot be applied in the absence of prima facie evidence of profit transfer outside India.
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