ITAT Judgment hyderabad: transfer pricing for non-covered ae transactions

Nikhil6810 Apr, 2026Business

The ITAT Hyderabad ruling on transfer pricing for non-covered AE transactions clarifies that margins agreed under a BAPA can be extended to similar transactions not explicitly covered, provided the Functions, Assets and Risks (FAR) remain identical. The Tribunal emphasized that transfer pricing is an economic exercise, and consistency must be maintained when no functional differences exist. This decision strengthens taxpayers position by recognizing BAPA margins as a reliable benchmark beyond their strict scope. SKMC Global supports businesses by preparing strong FAR analysis, ensuring accurate documentation and assisting in defending transfer pricing positions before tax authorities while maintaining compliance and reducing litigation risks.