On February 6th, 2025, the Delhi High Court made it clear that Mutual Agreement Procedure (MAP) settlements are not a blueprint for all. It ruled that the transfer pricing framework agreed between India and the US under the MAP cannot be extended to non-US transactions. By rejecting the ITAT’s directive to apply the same pricing approach to unrelated jurisdictions, the court reinforced that MAP outcomes are jurisdiction-specific and must not override the independent application of domestic transfer pricing rules.
