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Transfer Pricing Adjustment of Rs. ₹445 Crore quashed against Netflix India
Case Law Details
- Case Name
- Netflix Entertainment Services India LLP Vs DCIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Mumbai
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Netflix Entertainment Services India LLP Vs DCIT (ITAT Mumbai)
Conclusion: Since Netflix India functioned solely as a limited-risk distributor of access, not as a licensee of content or technology, therfore, TNMM benchmarking was accepted, and the royalty-based TP adjustment of ₹444.93 crores was unsustainable.
Held: Netflix Inc. (“Netflix US”), a US-based global streaming company, licenses its non-US operations to Netflix International B.V. (NIBV), Netherlands. In India, Netflix Entertainment Services India LLP (“Netflix India”) was incorporated to distribute access to the global N...
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