The appeal routes.
| Stage | Who decides | Time limit |
|---|---|---|
| First appeal (normal route) | Commissioner of Income-tax (Appeals) | 30 days from the demand notice |
| Alternative route | Dispute Resolution Panel, before the final order | 30 days from the draft order |
| Second appeal | Income Tax Appellate Tribunal (ITAT) | 60 days from the order |
| Question of law | High Court | 120 days from the ITAT order |
| Treaty route | Mutual agreement procedure with HMRC | Within three years of the first notice |
From 1 April 2026 the Income-tax Act, 2025 has renumbered the transfer pricing provisions. Cases for years before tax year 2026-27 still run under the Income-tax Act, 1961, so this page uses the familiar section numbers. We apply whichever Act covers your year.
After the DRP route, the appeal lies straight to the Tribunal. See Transfer Pricing DRP and Appeal at ITAT.
Common grounds.
- ComparablesWrongly included high-margin companies or wrongly rejected ones.
- FiltersTurnover, related-party and loss filters applied inconsistently.
- MethodA method that does not fit the transaction.
- Working capital and riskAdjustments for differences between the company and comparables.
- Intra-group servicesCharges disallowed for lack of evidence of benefit.
- Interest and guaranteesRates and fees on loans and guarantees to or from the UK.
MAP and double tax.
An Indian adjustment taxes profit the UK has already taxed. Under the India–UK treaty, the mutual agreement procedure lets the two tax authorities agree the price and remove double tax, and in some cases collection of the Indian demand can be suspended while MAP runs. We coordinate with your UK advisers on whether to pursue MAP, the appeal, or both.
How we work.
The order
Strength of each ground and the money at stake.
Appeal and stay
On time, with a stay application for the demand.
The paper book
Fresh comparables analysis and case law.
At the hearing
Represented by our Chartered Accountants.
Why UK companies choose us in India.
We work with your UK finance team, lawyers and auditors, and translate Indian requirements into plain English.
Every filing and certificate is checked by a second Chartered Accountant before it goes in.
A written scope, timetable and fee before work starts.
One calendar of every MCA, RBI, GST and income-tax deadline for your Indian entity.
Set-up, accounts, payroll, tax, audit and RBI filings handled together.
Encrypted document sharing and digital signatures. Directors never need to travel.
TP appeals for UK groups with Indian entities.
We support UK groups headquartered anywhere in the UK with transfer pricing for their Indian subsidiaries and branches, working with their UK tax teams online.
London
South East
Midlands
North of England
East and South West
Scotland, Wales, NI
Transfer pricing appeals FAQs.
Facing a transfer pricing adjustment?
Send us the order. We will assess the grounds, the route and the deadline.
This page is general guidance based on the Income-tax Act, 2025 and the rules and return forms as they stand. It is not legal or financial advice for your situation. Forms, eligibility and due dates can change each year, so please check with us before filing.