Transfer Pricing Adjustment of Rs. ₹445 Crore quashed against Netflix India

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...