DY COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

ITA 4873/MUM/2025Status: DisposedITAT Mumbai31 December 2025AY 2012-13Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal upheld the exclusion of Excel Infoways Ltd. as a comparable and directed the inclusion of Jindal Intellicom Ltd. The Tribunal also directed the Assessing Officer (AO) to allow working capital adjustment.

What were the facts?

The assessee, BP India Pvt. Ltd., provided back office and business support services to its parent company. The Transfer Pricing Officer (TPO) made an adjustment to the arm's length price (ALP) for these services. The assessee challenged the TPO's selection of comparable companies and adjustments.

What were the issues?

The key issues were the selection of functionally similar comparables for transfer pricing analysis and the allowance of working capital adjustments.

Which sections of the Income-tax Act were involved?

Section 92CA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES “K”, MUMBAI

Before: SHRI PAWAN SINGH & SHRI GIRISH AGRAWAL

For Appellant: Ms. Chandni Shah/ Mr. Amol, Ms. Nidhi Agarwal
For Respondent: Shri Bhagirath Ramawat (SR. D.R.)
Hearing: 11.12.2025Pronounced: 31.12.2025

Per : Pawan Singh, Judicial Member:

1.

This appeal by Revenue and Cross-Objection (CO) by Assessee are directed

against the order of Ld. CIT (A) 55 Mumbai dated 13.05.2025 for AY 2012-

2013.

The Revenue has raised following grounds:-

“1. "Whether on the fact and circumstances of the case and in

The order continues below.

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