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@article{184337,
        author = {MAMTA BHAWANISHANKER KHANDELWAL},
        title = {AI-DRIVEN SOLUTIONS FOR RESOLVING TRANSFER PRICING DISPUTES: OPPORTUNITIES AND ETHICAL CHALLENGES IN INDIAN LAW},
        journal = {International Journal of Innovative Research in Technology},
        year = {2025},
        volume = {12},
        number = {4},
        pages = {1004-1008},
        issn = {2349-6002},
        url = {https://ijirt.org/article?manuscript=184337},
        abstract = {This research explores the integration of artificial intelligence (AI) in resolving transfer pricing (TP) disputes in India, focusing on how AI tools can analyze tariff impacts, predict litigation outcomes, and ensure fairness while addressing ethical concerns such as data privacy and algorithmic bias. The central research question is: How can AI-driven solutions enhance TP dispute resolution in India under the Income Tax Act, 1961, and OECD guidelines, and what ethical challenges must be mitigated to ensure equitable implementation?
Employing a mixed-methods approach, including legal analysis of key provisions (Sections 92–92F of the Income Tax Act and OECD BEPS Actions), case studies of landmark disputes (e.g., GlaxoSmithKline, Vodafone), and review of AI applications in TP (e.g., predictive analytics for audit simulations), the study draws on secondary data from OECD reports, Indian tax statistics, and emerging AI literature. Quantitative insights are derived from TP litigation trends (2020–2025), revealing a 10–15% annual increase in disputes, with Mutual Agreement Procedures (MAPs) resolving cases faster than traditional litigation.
Findings indicate AI opportunities in reducing compliance costs by 20–30% through automated arm’s-length pricing analysis and outcome prediction accuracy of up to 85% in simulated audits. However, ethical challenges like algorithmic bias (e.g., perpetuating sector-specific disparities) and data privacy breaches under India's Digital Personal Data Protection Act, 2023, pose risks of unfair assessments. The study's originality lies in its India-specific nexus of AI, TP law, and ethics, bridging gaps in existing literature that overlooks AI's role in emerging markets. Its significance is in providing actionable insights for Assessing Officers (AOs) to leverage AI for efficient audits, policymakers for ethical guidelines, and MNEs for compliant strategies, ultimately fostering transparent tax administration and economic growth in India.},
        keywords = {Transfer pricing, Artificial Intelligence, Income Tax Act, OECD, Algorithmic bias, Data privacy, India.},
        month = {September},
        }