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India vs Xchanging Solutions Limited, April 2026, Income Tax Appellate Tribunal, Case No 385/Bang/2025

The Income Tax Appellate Tribunal, Bangalore partly allowed an appeal by Xchanging Solutions Limited for assessment year 2011-12, directing the assessing officer to exclude five comparables from the arm’s length price computation for software development services. The Tribunal found that an earlier ITAT direction to the Dispute Resolution Panel to reconsider those comparables had not been complied with in time.

India vs Xchanging Solutions Limited, April 2026, Income Tax Appellate Tribunal, Case No 385/Bang/2025 Read Post »

India vs American Express (India) Pvt. Ltd., May 2026, High Court of Delhi, Case No ITA 656/2019

The Delhi High Court decided a Revenue appeal concerning transfer pricing adjustments for Assessment Year 2009-10 in the case of a captive IT-enabled services provider. The court admitted two of seven proposed substantial questions of law and answered both in favour of the Revenue, directing the Transfer Pricing Officer to examine the functional comparability of Cepha Imaging Pvt. Ltd. and to exclude CG Vak Software and Exports Ltd. on account of an extreme turnover disparity.

India vs American Express (India) Pvt. Ltd., May 2026, High Court of Delhi, Case No ITA 656/2019 Read Post »

India vs Pernod Ricard India Pvt. Ltd., May 2026, Supreme Court, Case No SLP (Civil) Diary No 74598/2025

The Supreme Court of India dismissed the tax authority’s Special Leave Petition challenging a Delhi High Court ruling in favour of Pernod Ricard India Private Limited, on grounds of both delay and lack of merit. The petition was filed 384 days late and the Court found no good ground to interfere with the High Court’s order.

India vs Pernod Ricard India Pvt. Ltd., May 2026, Supreme Court, Case No SLP (Civil) Diary No 74598/2025 Read Post »

India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024

The Income Tax Appellate Tribunal, Ahmedabad allowed the appeal of Inductotherm (India) Pvt. Ltd. for statistical purposes, directing deletion of a transfer pricing adjustment of Rs.3,88,46,904 and remanding two further issues to the Assessing Officer for fresh adjudication. The Tribunal held that TNMM at entity level was the most appropriate transfer pricing method, consistent with coordinate bench decisions in the assessee’s own case for earlier assessment years.

India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024 Read Post »

Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE

The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNMM) as the most appropriate transfer pricing method for SABIC India Pvt Ltd. The Revenue, represented by the Principal Commissioner of Income Tax -7, challenged the Tribunal’s ruling, which annulled the adjustment of ₹3,61,32,20,620/- made by the Transfer Pricing Officer (TPO) using the residual “other method” under Rule 10B(1)(f) of the Income Tax Rules, 1962.

Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE Read Post »

General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi

The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The core issue concerned whether the assessee, an LLC, could be considered a “resident” for tax purposes under Article 4 of the India-USA DTAA

General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi Read Post »

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Compare Programmes

Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.

Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
Entry point Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits.

Awards Ladder

Award Best for What you achieve Assessment highlights
PG Certificate Foundation to intermediate upskilling Core concepts, frameworks, and applied techniques Short case write ups, timed responses, applied tasks
PG Diploma Expanding technical depth and application Advanced analysis, risk management, documentation quality Integrated case assignments, policy memos, oral defence
MSc Leaders and specialists building authority Capstone project and research backed practice outcomes Research project, viva or presentation, publishable summary

IFF Certificate Courses

Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.

Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected