The Pune Income Tax Appellate Tribunal recently issued a decision on whether an independent customs valuation may be accepted for transfer pricing purposes. The case involved India-based GKN Sinter Metals Pvt. Ltd., a manufacturer of metal powder precision components.
In the 2007-08 fiscal year, GKN purchased secondhand machinery from its associated enterprise GKN Sinter Metals Lichfield, UK. The transaction was selected for scrutiny and a notice was issued to GKN. In response, GKN held that…