Mutual Agreement Procedure is increasingly central to India's tax-certainty architecture. The real strategic mistake in 2026 may not be using MAP - it may be using it too late.
India’s APA regime has crossed the proof-of-concept stage. For large taxpayers in 2026, the real question is no longer whether a case can be fought, but whether recurring litigation still delivers more value than certainty.
Transfer pricing true-ups are not inherently suspect. But in India, a year-end margin correction becomes defensible only when contracts, monitoring, settlement and Rule 10D evidence all point to one coherent pricing policy.
India's transfer pricing fights over intra-group services have become too fixated on proving 'benefit' after the fact. A better test would ask what service was actually rendered, why it was needed, and whether it was priced credibly.
