AI-Powered Transfer Pricing Analytics: Enhancing Dispute Resolution in India and the Global South With Ethical Safeguards

Mamta Bhawanishanker Khandelwal

Abstract

This research investigates the application of artificial intelligence (AI) in optimizing transfer pricing (TP) dispute resolution, with a focus on India and comparative insights from the Global South, under the Income Tax Act, 1961, and OECD BEPS guidelines. Using a mixed-methods approach, the study integrates legal analysis, landmark case studies, and advanced AI techniques including machine learning regression models and blockchain-enabled audits. Findings reveal significant reductions in resolution time, enhanced predictive accuracy, and lower compliance costs, while identifying ethical challenges such as algorithmic bias and data privacy risks. The study offers an original, ethically grounded AI framework for TP analytics in emerging markets.

Keywords

Artificial Intelligence, Transfer Pricing, Dispute Resolution, Global South, Ethical Safeguards

Corresponding Author

Mamta Bhawanishanker Khandelwal, G.H. Raisoni University, Saikheda, India.

Citation

Khandelwal, M. B. (2025). AI-Powered Transfer Pricing Analytics: Enhancing Dispute Resolution in India and the Global South with Ethical Safeguards. Cognitive Computing & Extended Realities, 1(1), 01–10.