The ITAT Mumbai ruling in the Red Hat India case marks a significant win for taxpayers, where a ₹4.24 crore transfer pricing adjustment was deleted due to the TPO’s failure to follow earlier Tribunal directions on working capital adjustment. The decision reinforces that authorities must adhere to binding appellate orders and apply correct benchmarking principles. SKMC Global helps businesses build strong transfer pricing documentation, apply accurate adjustments and represent effectively in litigation to avoid prolonged disputes and unwarranted tax additions.
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