The CBDT has issued two important Circulars relating to Transfer Pricing law. The first bearing No. 02/2013 dated 26.03.2013 deals with the important issue of when the Profit Split Method can be applied in preference to the TNMM and CUP Methods. The second bearing No. 03/2013 dated26.03.2013 explains the circumstances required to be fulfilled for a development centre engaged in R&D activities to be considered to have "insignificant risk" for purposes of determining the ALP.
Both Circulars are a must-read for all tax professionals engaged in transfer pricing and international tax practice.