Transfer pricing is the most contentious tax issue, fact-intensive and judgmental, involving difficult evaluation of comparability, market, and financial information. Principles involved for such evaluation are also very complex. The book aims at explaining those principles as contained in Indian law and OECD Guidelines, 2010, and as exposed by the Indian and foreign courts. It deals extensively and comprehensively , amongst others, with the following :

Comparability and degree of comparability and comparable adjustments.
Methodolgies, their salient features, selection of most reliable method, comparables and adjustments.
Intangible property.
Intra- group services.
Cost Contribution Agreement.
Business restructuring.
Safe harbour.
Advance Price Agreements.
International transaction and specified domestic transactions.
Associated enterprises.
Documentation.
Determination of ALP and computation of income.
Penalties for non-compliance.
Interpretative principles