Transfer Pricing Appeals
Not every assessment goes your way. And when adjustments are made, the real question is, do you accept it or challenge it?
A well-handled appeal can reverse or significantly reduce the impact of a transfer pricing adjustment. But it needs more than just paperwork. It needs a clear position, strong reasoning, and the ability to present your case effectively.
At N D Savla & Associates, we help you challenge transfer pricing additions with a structured, practical approach.
What this really means for you
If a transfer pricing adjustment has been made during assessment, you have the right to appeal.
This could involve:
Disputing benchmarking conclusions
Challenging method selection
Questioning comparables used by the tax officer
Arguing on functional differences or risk profiles
But here’s the thing, appeals are not about repeating your documentation. They’re about reframing your case in a way that stands up legally and logically.
Where businesses usually get stuck
Grounds of appeal are drafted too broadly or too weak
Arguments lack technical depth
No clear strategy across multiple levels (CIT(A), ITAT, etc.)
Inconsistent positions between assessment and appeal
And once the appeal is poorly structured, it limits your chances later.
Our Approach
We focus on building a case that holds, not just filing an appeal.
1. Case Evaluation
We review the assessment order and identify where the adjustment can be challenged.
2. Strategy & Positioning
We define clear grounds of appeal and align them with legal precedents and facts.
3. Documentation & Drafting
Preparation of appeal documents with strong technical and practical arguments.
4. Representation Support
Handling submissions and discussions before appellate authorities.
5. Ongoing Guidance
Advising on next levels of appeal if required and ensuring consistency in approach.
Why Clients Work With Us
We combine technical knowledge with practical experience
We focus on winning arguments, not just detailed documents
We keep your case consistent across all stages
We stay involved until resolution, not just filing
When Should You Consider an Appeal?
You disagree with transfer pricing adjustments
Your benchmarking has been rejected or modified
Inappropriate comparables have been used
You want to reduce tax impact and penalties
F.A.Q.
It is the process of challenging an adjustment made by tax authorities during transfer pricing assessment.
Typically before the Commissioner of Income Tax (Appeals), and further to ITAT if required.
Generally, appeals must be filed within 30 days from receipt of the assessment order.
Yes, provided there are valid legal and factual grounds to support your position.
Assessment order, transfer pricing documentation, supporting evidence, and detailed grounds of appeal.
We evaluate your case, build strong appeal grounds, and represent you through the process to improve your chances of a favorable outcome.
