An Inter-Disciplinary Study of GST and Transfer Pricing

Poonam Harjani & Ashutosh Mishra – [2022] 136 taxmann.com 303 (Article)

In physiological studies, the concept of ‘subliminal messaging’ is explained as an approach getting into a person’s system without the person being truly aware of it. Thus, subliminal messaging influences without realization. The Indian taxation regime also seems to follow a similar approach wherein provisions of different taxation laws applicable simultaneously on the same transaction tend to create contentious legal issues.

With certain provisions in Income-tax, particularly, Transfer Pricing and GST sharing common characteristics of being transaction level taxes and valuation being a binding factor for both; it becomes imperative to analyse the loopholes and conundrums both the laws present when acting together and thus, arises the need for an inter-disciplinary study for the same. In this article, the authors analyse transaction of corporate guarantee and how it would be affected by the inter-play of transfer pricing and GST provisions.

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