Budget 2026 : Transfer Pricing Dispute Resolution Timelines
02 Feb 2026
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The time barring of the transfer pricing and non-resident assessment cases has emerged as a contentious topic in the Indian dispute resolution regime (popularly known as Roca Bathroom[1] or Shelf Drilling[2] case). The two-member bench of Supreme Court had delivered a split verdict and referred the matter to a larger bench. While the matter may still be under sub-judice, the Government recognising the gravity of the matter, through 2026 Budget decided to step in and restrospectively amend the law in itself.
