ITAT deletes ₹445 cr TP adjustment on Netflix India; rejects revenue’s bid to treat it as content or tech entrepreneur

Mumbai: 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 ₹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.