India: Transfer Pricing

The Delhi High Court's recent ruling in the Ernst & Young U.S. LLP case has reignited the debate over cross-border employee secondments, determining that reimbursed salary costs constitute taxable technical services rather than mere fiscal pass-throughs. This decision, which closely mirrors the foundational Centrica India Offshore precedent, establishes that seconded employees who retain employment liens and social security benefits with their overseas entities remain employees of the foreign entity, thereb

India's data centre and cloud infrastructure sector is experiencing unprecedented growth, driven by explosive data generation, digital transformation across industries, and fiscal incentives introduced in the Union Budget...

It is oft said that statutes are many spender things – they are so tightly and precisely defined, that the Judiciary's predictive task is quite straightforward.