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Oct 30, 2025
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ITAT deletes Rs 445 cr TP adjustment on Netflix India; rejects revenue’s bid to treat it as content or tech entrepreneur
The Income Tax Appellate Tribunal (ITAT) has rejected the income-tax department’s bid to treat Netflix India as a full-fledged content and technology service provider, and deleted a Rs 444.93-crore transfer pricing adjustment for 2021–22, in a major relief for multinational digital platforms.
The Mumbai bench of the tribunal held that Netflix Entertainment Services India LLP (Netflix India) operates merely as a limited-risk distributor of access to the Netflix streaming service, with no ownership of intellectual property (IP) or control over content or technology.
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