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Hyundai Motor India Receives Favourable ITAT Order for FY 2007-08 Transfer Pricing Case
Hyundai Motor India Ltd. (HMIL) has received an order from the Income Tax Appellate Tribunal (ITAT) for a case concerning transfer pricing adjustments from FY 2007-08. The Tribunal’s latest decision has ruled in favour of the company, removing the previously imposed adjustment.
Keshav Rajput
Updated Oct 13, 2025, 11:41 AM IST
Hyundai Motor India Receives Favourable ITAT Order for FY 2007-08 Transfer Pricing Case
Recently, in a Regulatory filing, Hyundai Motor India Ltd. informed the National Stock Exchange (NSE) and the Bombay Stock Exchange (BSE) about an order received from the Income Tax Appellate Tribunal (ITAT). The matter relates to a transfer pricing dispute for the financial year 2007-08 (assessment year 2008-09).
"It has been alleged that the rate of royalty paid (as a percentage of sales) by the Company is more than the industry average rate, resulting in a Transfer Pricing adjustment (‘TP adjustment’) by the Transfer Pricing Officer (‘TPO’) for the FY 2007-08 (AY 2008-09)," Automaker said in the filing.
Earlier, the Transfer Pricing Officer (TPO) had adjusted the royalty rate paid by the company, stating it was higher than the industry average. This led to a total adjustment of Rs 86.88 crore, which was later reduced to Rs 21.83 crore after appeal.
Miscellaneous Petition Filed by the Company
Following the partial relief, Hyundai Motor India has filed a Miscellaneous Petition before the ITAT, highlighting discrepancies in the earlier order issued in December 2024. The petition requested rectification and review of those points.
Tribunal’s Decision
In its order dated October 7, 2025, the ITAT accepted the company’s submissions after reviewing the matter. The Tribunal has now ruled completely in favour of Hyundai Motor India, deleting the entire transfer pricing adjustment.
on October 1, 2025, The Korean automaker has also started production of passenger vehicles at its Talegaon manufacturing plant. The facility has an annual installed production capacity of 1,70,000 units.
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