ITAT Deletes ₹445 Crore Transfer Pricing Adjustment Against Netflix India
The Income Tax Appellate Tribunal (ITAT) has ruled in favor of Netflix India, rejecting a ₹445 crore transfer pricing adjustment. The tribunal affirmed Netflix India's role as a limited-risk distributor of streaming access, not a content provider.
The Income Tax Appellate Tribunal (ITAT) Mumbai has dismissed a ₹445 crore tax demand against Netflix India, rejecting the tax department's attempt to classify it as a full-fledged content provider. The tribunal upheld Netflix India's use of the Transactional Net Margin Method for benchmarking, noting its activities are limited to promotion, marketing, invoicing, customer support, and regulatory compliance. This decision provides clarity for multinational digital and OTT companies operating under limited-risk models in India.
