DRP issues transfer pricing directions for AY 2023-24; most objections not accepted, final order awaited

Received DRP-2 Directions under section 144C(5) of the Income-tax Act in transfer pricing proceedings for FY 2022-23 (AY 2023-24).

Fri 2 Oct 2026

Proposed Transfer Pricing Adjustment

INR 3,84,17,653

Assessment Year / Financial Year

FY 2022-23 (AY 2023-24)

DRP Directions Date

30 September 2026

Statutory Provision

section 144C(5) of the Income-tax Act, 1961

DRP Outcome

Most objections not accepted; AO directed to include findings in the final order, which is awaited

What the company disclosed

DIC India Limited has informed the exchanges that it received Directions dated 30 September 2026 from Dispute Resolution Panel-2 (DRP), New Delhi, issued under section 144C(5) of the Income-tax Act, 1961. The directions relate to transfer pricing proceedings for FY 2022-23 (Assessment Year 2023-24) and follow the objections the company had shared against the draft assessment order.

What a transfer pricing adjustment means

• Tax authorities review the prices at which a company transacts with its overseas group entities.
• If they consider the price to be not at arm's length, they propose an upward adjustment, which adds to the company's taxable income.
• The draft assessment order in this case involved an upward transfer pricing adjustment of INR 3,84,17,653 for AY 2023-24.

What the DRP said

• The DRP did not accept most of the company's objections.
• It directed the Assessing Officer to incorporate its findings in the final order.
• The final assessment order giving effect to the directions is awaited from the Assessing Officer.

The company's stated position

• No violation(s)/contravention(s) have been committed by the company, as stated in the disclosure.
• No penalty or restriction has been imposed as of date.
• Since the final order is awaited, the company states there is no financial or other impact as of date.
• The company states it will evaluate the final order and take appropriate action once received.

What investors may watch for

• The final assessment order from the Assessing Officer, which will give effect to the DRP's directions.
• Any consequent tax demand or provision, which would be known once that order is received.
• The period involved is FY 2022-23 (AY 2023-24), so the matter concerns one assessment year.

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