In Doshi Accounting Services vs. DCIT, the Special Bench of the ITAT has held that the transfer pricing provisions are applicable even to a case in which the income of the assessee is eligible for 100% tax exemption and is not chargeable to tax in India. Advocate Shashi Bekal has conducted an in-depth analysis of the judgement and explained its nuances. He has also argued that the judgement may require reconsideration