Need expert advice on the thoughts of Indian tax authorities on transfer pricing vs cost plus arrangement?

India has taken extreme transfer pricing views that more profit should be captured in India, either by arguing for higher cost plus markups, favoring profit split methods, or arguing for location savings intangibles, all of which tend to capture more profit there. The result has been more unresolved double taxation cases between India and the US to the point where U.S. Competent Authority Mike Danilack, who heads the group that negotiates such cases with their Indian tax counterparts, has openly criticized the unreasonable Indian positions and is currently rejecting U.S. taxpayer requests for bilateral Advance Pricing Agreements (APAs) with India, until the Indian Competent Authority assumes more reasonable positions in U.S.-India transfer pricing disputes.