Aggregation of Sales Allowed in Indian Transfer Pricing Case

The Mumbai Income Tax Appellate Tribunal has recently ruled that the aggregation of similar related-party transactions is to be allowed in determining arm's length transfer pricing.

Case

The case involved an India taxpayer that sold hot-rolled iron coils to a related party in Indonesia through multiple transactions. In determining the arm's length price, the taxpayer aggregated all the transactions and used the CUP method. The result was comparable to the average sales price of the same p…