APA vs Litigation in 2026: When Should Large Taxpayers Stop Fighting?
India’s APA regime has crossed the proof-of-concept stage. For large taxpayers in 2026, the real question is no longer whether a case can be fought, but whether recurring litigation still delivers more value than certainty.
Transfer Pricing True-Ups at Year-End: Commercial Hygiene or Audit Trigger by Design?
Transfer pricing true-ups are not inherently suspect. But in India, a year-end margin correction becomes defensible only when contracts, monitoring, settlement and Rule 10D evidence all point to one coherent pricing policy.
Intra-group services: India’s benefit-test obsession is becoming a tax-certainty problem
India's transfer pricing fights over intra-group services have become too fixated on proving 'benefit' after the fact. A better test would ask what service was actually rendered, why it was needed, and whether it was priced credibly.
When AMP Spend Does – And Does Not – Look Like a Marketing Intangible Issue
Local marketing spend in India often sits inside routine distribution economics. The harder question is whether the taxpayer can prove who controlled that spend, who bore the risk, and who kept the commercial upside.
DEMPE Analysis Is Turning Formulaic—and That’s Becoming a Transfer Pricing Risk
DEMPE analysis is becoming harder to fake. As transfer pricing audits mature and routine disputes get simplified, template-heavy intangible files are increasingly exposed as evidence-light and adjustment-prone.
