AstraZeneca Pharma India Limited, a leading pharmaceutical company in the country, has announced a favorable development in a long-standing tax dispute. On April 14, 2025, the company received the final Order Giving Effect to a decision by the Hon’ble Income-tax Appellate Tribunal (ITAT) concerning the assessment year 2014–15.

This final order, issued under Section 143(3) read with Section 254 and Section 144C of the Income Tax Act, 1961, brings significant relief to the company. It deletes major adjustments related to transfer pricing and corporate tax issues that were raised in an earlier draft order. The quantum of the tax relief granted amounts to approximately ₹35.22 crore, excluding interest.

The company had previously disclosed the draft order related to the same assessment year to the stock exchanges via its letter dated March 22, 2025, in accordance with Regulation 30 of SEBI’s Listing Obligations and Disclosure Requirements (LODR) Regulations, 2015. This latest update is a continuation of that disclosure, fulfilling the requirements under SEBI Circular SEBI/HO/CFD/CFDPoD-1/P/CIR/2023/123 dated July 13, 2023.

Details of the Tax Litigation:

• Opposing Party: Assistant Commissioner of Income Tax

• Tribunal Involved: Hon’ble Income-tax Appellate Tribunal (ITAT)

• Nature of the Dispute: The original tax assessment involved major transfer pricing and corporate tax adjustments. These adjustments have now been entirely deleted in the final ITAT order.

• Financial Impact: The tax relief amounts to ₹35.22 crore, excluding accrued interest. There are no additional claims, penalties, or compensations arising from the current order.

• Status: This is a final order, not an ongoing litigation.

Implications for AstraZeneca Pharma India:

This favorable ruling from the ITAT provides substantial financial relief to the company, strengthening its financial position and resolving a decade-old tax matter. With ₹35.22 crore in tax relief, AstraZeneca Pharma India can reallocate resources more effectively and focus on its core business activities, including drug development, healthcare partnerships, and R&D investments.

Moreover, the deletion of transfer pricing adjustments signals a positive precedent for multinational pharmaceutical firms operating in India, especially those facing scrutiny over cross-border transactions. AstraZeneca Pharma’s successful appeal demonstrates the importance of robust documentation, compliance, and perseverance in such cases.

Regulatory and Market Transparency:

By disclosing the development promptly under SEBI Regulation 30, AstraZeneca Pharma India continues to maintain high standards of corporate governance and transparency. The inclusion of the matter in the company’s public disclosures ensures stakeholder awareness, including that of shareholders, regulators, and market participants.

The company's secretary, Manasa R, signed off the disclosure communication addressed to the BSE and NSE on April 14, 2025. The regulatory filing has also included Annexure A, outlining the required details under the SEBI circular dated July 13, 2023.

Background of the Case:

The assessment year in question—2014–15—involved transfer pricing adjustments, a common area of contention for multinational companies. The Income Tax Department had raised significant demands, later challenged by AstraZeneca Pharma at the Income-tax Appellate Tribunal.

The tribunal’s decision to delete the contentious adjustments reflects a judicial acknowledgment of the company’s arguments and its compliance with Indian tax laws. The relief also confirms that no additional tax liability or penalties are to be levied for the said period.

Conclusion:

This ruling marks a major legal and financial win for AstraZeneca Pharma India Limited. It reflects not just a successful resolution of a complex tax matter, but also the company’s ongoing efforts to maintain transparency, fiscal responsibility, and corporate compliance.

As the company continues to grow and serve patients across India, this positive outcome adds confidence to its financial health and operational integrity. Investors and stakeholders can take reassurance in the company’s ability to manage regulatory challenges efficiently, while staying focused on its mission of advancing healthcare and innovation.