Trilegal Successfully Represented Samsung SDI India Before ITAT in Transfer Pricing Dispute
The leading Indian law firm Trilegal successfully represented Samsung SDI India before the Income-tax Appellate Tribunal (ITAT), Delhi, in significant transfer pricing appeals concerning the applicability of the Berry Ratio as the profit level indicator (PLI) for benchmarking international transactions undertaken by a low-risk distributor.
The ITAT ruled in favour of Samsung SDI India, holding that the company acts as a mere facilitator without undertaking any risks related to inventory, warehousing, or similar functions. Accordingly, the assessee qualifies as a low-risk distributor, making the Berry Ratio an appropriate PLI in this case.
The Trilegal Taxation team was led by Himanshu S. Sinha (Partner), with support from Prashant Meharchandani (Counsel), Kanika Jain (Associate), and Jainender Singh Kataria (Associate).
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