Xchanging Solutions Secures Partial Victory in ITAT Transfer Pricing Appeal
Xchanging Solutions Limited has achieved a partial victory in its transfer pricing appeal, with ITAT Bangalore partly allowing the company's case for Assessment Year 2011-12. The tribunal directed recomputation of the ₹4.52 crore transfer pricing adjustment after excluding certain comparable companies from the arm's length price determination. The company has confirmed no material financial or operational impact from this favorable ruling.

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Xchanging Solutions Limited, a DXC Technology Company, has secured a partial victory in its transfer pricing litigation case, with the Income Tax Appellate Tribunal (ITAT) Bangalore delivering a favorable ruling on April 06, 2026.
ITAT Order Details
The tribunal partly allowed the company's appeal for Assessment Year 2011-12, providing significant relief in the ongoing transfer pricing dispute. The order addresses the company's challenge against the Final Assessment Order that had imposed transfer pricing adjustments.
| Parameter | Details |
|---|---|
| Tribunal | Income Tax Appellate Tribunal (ITAT), Bangalore |
| Order Date | April 06, 2026 |
| Assessment Year | 2011-12 |
| Original Adjustment Amount | ₹4.52 crore |
| Appeal Status | Partly Allowed |
Key Tribunal Directions
The Hon'ble Tribunal has provided specific directions to the Assessing Officer regarding the recomputation of transfer pricing adjustments. The tribunal ordered the exclusion of certain comparable companies that were previously considered for determining the arm's length price, which formed the basis for the original assessment.
This directive requires the Assessing Officer to:
- Exclude specific comparable companies from the transfer pricing analysis
- Recompute the transfer pricing adjustment based on the revised comparable set
- Reassess the arm's length price determination methodology
Financial and Operational Impact
The company has explicitly stated that the ITAT order will have no material impact on its financial position or operational activities. This disclosure provides clarity to investors and stakeholders regarding the limited effect of the tribunal's decision on the company's business operations.
| Impact Assessment | Status |
|---|---|
| Financial Impact | No material impact |
| Operational Impact | No impact |
| Business Activities | No impact |
Regulatory Compliance
Xchanging Solutions has fulfilled its disclosure obligations under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The company provided comprehensive details as required under the regulatory framework, ensuring transparency with stakeholders regarding the litigation development.
This development represents a continuation of the transfer pricing case that was initially disclosed in the company's letter dated December 31, 2024, demonstrating the company's commitment to keeping investors informed about material legal proceedings and their outcomes.
Historical Stock Returns for Xchanging Solutions
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +0.60% | +6.04% | +18.04% | -23.01% | -26.72% | +4.44% |
Will this ITAT precedent influence transfer pricing strategies for other DXC Technology subsidiaries in India?
How might the exclusion of comparable companies affect future transfer pricing assessments across the IT services sector?
Could this partial victory encourage Xchanging Solutions to challenge similar transfer pricing adjustments for other assessment years?


































