ITAT Rajkot Quashes Transfer Pricing Additions in Specified Domestic Transactions

Author : skmcglobal 16068 | Published On : 03 Mar 2026

ITAT Rajkot Landmark Ruling: Deleting Transfer Pricing Adjustments in Specified Domestic Transactions highlights a significant decision where the tribunal struck down TP additions made without proper benchmarking and functional comparability analysis. The ruling emphasized that Specified Domestic Transactions must strictly satisfy Section 92BA conditions and that adjustments cannot be based on assumptions or inadequate comparable data. It reinforced the importance of arm’s length pricing and placed the burden on tax authorities to justify deviations with evidence. This decision strengthens taxpayer protection in domestic TP matters. SKMC Global supports businesses with robust TP documentation, benchmarking studies, compliance review, and litigation representation to mitigate risks and ensure defensible transfer pricing positions.