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

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.

Hyundai Bayon

Ex-Showroom Price

₹ 9.99 Lakh

Also Read: Creta Records Highest Ever Monthly Sales As Hyundai India Posts 10 Percent Growth in September 2025

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.

Also Read: 4 Mahindra SUVs to Buy in India Under Rs 10 Lakh

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.

Hyundai Bayon

Miscellaneous Petition Filed by the Company

Tribunal’s Decision

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