Abstract
Abstract The transfer pricing has a significant role to play in terms of taxation of income from intangibles in case of intercompany transfer pricing in today’s world. With special reference to the Shell case which is a wholly owned subsidiary of the Royal Dutch Shell Group, the amalgamation of two rival companies: Royal Dutch Petroleum Company and the ‘Shell’ Transport and Trading Company Ltd of the United Kingdom. The case focuses on the court decision came in favour of Shell India challenged the order of the Income Tax Appellate Tribunal, to circumvent transfer pricing norms, though it was an international transaction wherein there was no arm’s length dealing between the related entities.
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