The growth in number and size of MNCs has brought a number of opportunities, a part from faster economic development. At the same time, the MNCs have also brought a number of problems to face. The scope of MNCs has widened in recent years so much that now more than 60% of the international transactions of the globe belong to MNCs. This has constrained the governments to keep in place proper mechanism to plug the leakage of tax revenue as a result of manipulative pricing policies adopted by these related parties (MNCs). Relevant provisions have been introduced under the Income Tax Act as early as 2001 itself and subsequently, the provisions were modified time to time. In 2012 Advance Pricing Agreements (APAs) and in 2014 Safe Harbour Rules (SHRs) were introduced to overcome the drawbacks of transfer pricing regulations. But still, the issue of transfer pricing is the most conflicted tax area. The government and the corporates want to be away from conflicts, but the transfer pricing audits have become a source of conflicts, in this background the paper discusses the transfer pricing mechanism adopted in India and based on the survey of 50 corporate houses, it comes out with the pulse-beat of the corporates about issue concerning Transfer Pricing in India. The paper analyses the findings and highlights the issue to be attended by the government to make the transfer pricing regime taxpayer friendly.
Keywords: Multinational Corporations, Income Tax Act, Transfer Pricing, Advance Pricing Agreement, Safe Harbour Rules, Tax Revenue,