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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