Relief For Titan: ITAT Deletes ₹6318 Crore Transfer Pricing Adjustment, Accepts Product Mix And Segmental Margin Analysis

The ITAT granted relief to Titan by deleting a ₹6318 crore transfer pricing adjustment, accepting the company’s product mix and segmental margin analysis. The article highlights the significance of segment-wise and product-wise analysis in multinational transfer pricing disputes. It also emphasizes the judiciary’s role in ensuring fair assessment methodology while interpreting international tax principles. The ruling reinforces that tax authorities must adopt a reasoned approach aligned with commercial reality and documented evidence.