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Transfer PricingArticle·10 August 2026

TP issues on Entity level TNMM admitted

By J the App

Executive Summary

The Bombay High Court, by its order dated 5 August 2026, admitted the Revenue's appeal against the ITAT's transfer pricing ruling in the case of Cummins India Ltd. 

The Court held that important questions of law concerning entity-level benchmarking under TNMM, aggregation of domestic and international transactions, and the interpretation of Section 92 warrant detailed consideration.

Domain | Direct Tax | Transfer Pricing

Background

The respondent, Cummins In...

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