Executive One-Pager – Transfer Pricing Case Law Update

Requirement of Transaction-Specific Benchmarking - No Blanket Validation Across Inter-Company Dealings <br><br>Delhi ITAT in the case of Honda R&D (India) Private Limited v. DCIT ITA No.4930/DEL/2024 Dated 8 October 2025<br><br>The Delhi ITAT has reiterated that each international transaction must be benchmarked independently under the transfer pricing framework. The Tribunal remanded the matter for fresh examination, emphasizing that acceptance of one transaction as being at armu2019s length does not automatically validate other related transactions embedded in the same financials.

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Executive One-Pager – Transfer Pricing Case Law Update

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