Transfer pricing adjustment recomputed and reduced to ~Rs. 3.74 crore for AY 2023-24 after DRP directions
Final transfer pricing order received after DRP-2 directions: upward income adjustment for AY 2023-24 reduced to ~Rs.
By ScoutQuest · · 2 min read
- Revised transfer pricing adjustment
- ~Rs. 3.74 crore
- Earlier adjustment
- ~Rs. 3.84 crore
- Assessment Year
- AY 2023-24
The company has disclosed a fresh transfer pricing order for Assessment Year 2023-24, the year covering its international transactions in FY 2022-23.
What the order says
- The order was passed by the Deputy Commissioner of Income Tax, Transfer Pricing - 1, Kolkata on October 22, 2026, and was received by the company's key managerial personnel on October 23, 2026 at 11:03 AM.
- It follows directions issued by the Dispute Resolution Panel-2 (DRP), New Delhi under Section 144C(5) of the Income-tax Act, 1961.
- The upward adjustment to the company's income, earlier fixed at ~Rs. 3.84 crore by an order dated January 22, 2026, has been recomputed and reduced to ~Rs. 3.74 crore.
- The revised total arm's length price adjustment for AY 2023-24 is therefore ~Rs. 3.74 crore.
What the company has stated
- On a preliminary assessment of the order, it expects no financial implication.
- It has stated that no violation or contravention has been committed by the company.
- It has stated that no penalty or restriction has been imposed as of date.
- It is evaluating the order and prefers to file an appeal before the appropriate authority within the stipulated time.
What a transfer pricing adjustment means
- Large companies transact with related entities abroad, such as group companies. Tax rules require those transactions to be priced as if the parties were unrelated, at what is called an arm's length price.
- If the tax officer believes the price charged was not at arm's length, the officer adds the difference back to the company's taxable income. That addition is the upward adjustment reported here.
- A higher adjustment generally means more income is treated as taxable in India.
What to take away
- The adjustment has moved down by a comparatively small margin from the earlier figure, but it remains an upward adjustment of ~Rs. 3.74 crore for the year.
- The company's own reading is that there is no expected financial implication, and it has flagged a possible appeal, which means the matter is not necessarily closed.
- The update also states that no penalty or restriction has been imposed as of date.
Also from DIC India
Income Tax survey at registered office; alleged non-update of SFT return in Form 61A
15 Oct 2026
CRISIL A/Stable and CRISIL A1 reaffirmed on DIC India's Rs.100 crore bank facilities and Rs.50 crore short-term debt
15 Oct 2026
DRP issues transfer pricing directions for AY 2023-24; most objections not accepted, final order awaited
2 Oct 2026
More numbers
- Earlier upward adjustment in income for AY 2023-24Rs. 3,84,17,653/-
- Revised upward adjustment for AY 2023-24Rs. 3,74,35,142/-
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