Indian Tribunal Holds APA Conditions may be Applied for Years Not Covered by the APA

The Delhi Income Tax Appellate Tribunal recently issued a decision on whether the conditions of an advanced pricing agreement (APA) should be accepted for a previous year not covered by the APA. The case involved Ranbaxy Laboratories Ltd., a pharmaceuticals manufacture that is engaged in transactions with several foreign associated enterprises. For the year at issue, Ranbaxy selected the foreign associated enterprises as tested parties for its transfer pricing study. In reviewing the study, t…