Company Registration 21 September 2026
Mumbai ITAT Upholds Aggregation Approach, Picks Foreign AE
The Mumbai Income Tax Appellate Tribunal (ITAT) has upheld the aggregation method for tax assessments and confirmed the selection of a foreign assessing authority (AE) as the tested party in the dispute involving RSM India Private Limited and the Deputy Commissioner of Income Tax. The ruling clarifies that foreign AEs can be designated for testing, providing greater certainty for multinational enterprises operating in India and reinforcing the tribunal's stance on aggregation in complex tax matters.
Key outcome: The Mumbai ITAT affirmed the aggregation approach and approved the selection of a foreign assessing authority (AE) as the tested party in the RSM India case.
- The tribunal examined the dispute between RSM India Private Limited and the DCIT, focusing on tax compliance procedures.
- Decision reinforces that foreign AEs can be designated for testing, offering clarity for multinational firms.
Read the full notice here.
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