TY  - GEN
AU  - SHAH, DHINAL ASHVINBHAI
TI  - CBDT circulars on transfer pricing of contract R&D centres: More questions than answers
PY  - 2013///
KW  - TAXATION
N2  - Characterzation of development centers of multinational companies (MNC) in India has been a vexed issue for a considerable time . While the MNCs contend that are contract R&D service providers bearing insignificant or risk free entities, the Transfer pricing officers (TPOs) have been treating them as full or significant risk bearing entities- thus attributing a higher markup for the functional and risk profile borne by them
ER  -