The Delhi High Court (HC) issued a judgment on 6 February 2025 concerning whether the transfer pricing framework agreed to under the mutual agreement procedure (MAP) of a tax treaty may be extended to similar transactions not covered by the MAP agreement. The case involved an Indian company that was engaged in transactions with related parties in the U.S. and certain other countries. The transfer pricing framework for transactions with the U.S. was covered by a MAP agreement made under the terms of the India-U.S. tax treaty. In assessing the related-party transactions with other countries, the transfer pricing officer was...