Arms length price for subsidiary company of a foreign based company established for supporting marketing for holding company

Last updated: 25 September 2012

Court :
INCOME TAX APPELLATE TRIBUNAL

Brief :
The facts in brief: The assessee M/sVerizon (India) P.Ltd. is a wholly owned Subsidiary of MCI WorldCom Asia P.Ltd. (hereinafter referred to as MCI), a Hongkong based Private Limited Company. The Holding Company MCI WorldCom Asia P.Ltd. is a preeminent global communication company for the digital generation, operating in more than 65 countries with 2000 revenues of approximately 540 billion. WorldCom provides the innovative technologies and services which primarily include high quality, long distance, internet data and international communication services across a seamless global telecom network. The company has established itself as a local network facilities based competitor in more than 21 countries throughout Europe, North and South America and the Asia-Pacific region.

Citation :
Dy.CIT, Circle 17(1) Room 221, C.R.bldg. New Delhi (Appellant) Vs. M/s MCI Com India P.Ltd. (Now known as Verizon India P.Ltd.) C-56, Neetibagh New Delhi 110 049(Respondent)