286 (Del- Tri), Stryker Global Technology Centre Private Limited v. DCIT
84 Taxmann.com 154Reported decision2017#10773 most cited
What is 286 (Del- Tri), Stryker Global Technology Centre Private Limited v. DCIT authority for?
When assessing transfer pricing, factors such as huge turnovers compared to the tested entity, close group connections, payments for brand equity, and lack of segmental bifurcation between services are relevant considerations.
10
judgments rely on this decision, according to BharatTax’s citation analysis of 366,405 Indian tax judgments — from 2018 to 2026.
Also referred to as
Stryker Global Technology Centre Private Limited · DCIT · 2017 · 84 Taxmann.com 154 · transfer pricing · arm's length price · comparable uncontrolled transactions · group companies · brand equity · segmental bifurcation · AY 2010-2011 · turnover