ITAT Judgment Guwahati Ruling on Mahalaxmi Continental Ltd : Key Transfer Pricing Insights

Author : skmcglobal 16068 | Published On : 14 Apr 2026

The ITAT Guwahati ruling in Mahalaxmi Continental Ltd. emphasizes that while TNMM is a valid transfer pricing method, its correct application is critical. The Tribunal highlighted that selecting functionally dissimilar comparables, ignoring risk profiles, and not granting proper working capital adjustments can distort the Arm’s Length Price (ALP). It reinforced the need for accurate benchmarking and economic consistency under Section 92C. SKMC Global helps businesses with robust FAR analysis, appropriate comparable selection and strong transfer pricing documentation, while also assisting in litigation support to defend positions and ensure compliance.