Indian Tribunal Holds Projected Figures Cannot be Replaced with Actual Figures for IP Transaction Valuation Adjustment

In a recently published decision, The Hyderabad Income Tax Appellate Tribunal ruled on whether a transfer pricing officer can replace projected cash flows with actual cash flows for transfer pricing purposes. The case involved India-based DQ International Ltd. (DQ India), a producer of animation, game art and other media content.

In the year concerned, DQ sold the IP rights for an animated series to an associated enterprise, DQ Entertainment Ireland (DQ Ireland). In determining the arm's len…