Hyundai Motor India ITAT Rules in Favor, Deletes TP Adjustment

Hyundai Motor India has received a favorable order from the Income Tax Appellate Tribunal (ITAT) regarding a Miscellaneous Petition for FY 2007-08. The ITAT ruled in the company’s favor, deleting the entire Transfer Pricing (TP) adjustment initially alleged. This decision is expected to result in a refund position for Hyundai. The company anticipates no material impact on its financial or operational activities.

Favorable Ruling from ITAT

Hyundai Motor India announced that the Income Tax Appellate Tribunal (ITAT) has passed an order in its favor on October 8, 2025, concerning a Miscellaneous Petition related to FY 2007-08. This decision follows an earlier intimation dated December 11, 2024.

Background of the Dispute

The dispute originated from allegations that the royalty rate paid by Hyundai Motor India, as a percentage of sales, exceeded the industry average. This led to a Transfer Pricing (TP) adjustment by the Transfer Pricing Officer (TPO) for FY 2007-08 (AY 2008-09).

Initially, Hyundai appealed against this adjustment, and the total TP adjustment was reduced from Rs. 86.88 crores to Rs. 21.83 crores. Subsequently, the company filed a Miscellaneous Petition before the ITAT, pointing out certain discrepancies in the order.

ITAT Decision and Impact

Following verification, the ITAT accepted Hyundai’s arguments and ruled in favor of the company. The entire Transfer Pricing (TP) adjustment has been deleted as per the current order dated October 7, 2025. The ITAT’s favorable decision is expected to lead to a refund for the company.

Hyundai Motor India believes this ITAT order will have no material impact on its financial or operational activities.

Source: BSE

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