LINTAS INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT, CIRCLE 16(1), MUMBAI

ITA 5889/MUM/2024Status: DisposedITAT Mumbai19 November 2025AY 2021-22Bench: SHRI NARENDER KUMAR CHOUDHRY (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)25 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the Dispute Resolution Panel (DRP) relied on previous year's orders, while a coordinate bench had remanded similar issues for fresh determination. Therefore, the Tribunal decided to remand the issue of GSA services back to the TPO for fresh benchmarking.

What were the facts?

The assessee, an advertising agency, engaged in international transactions with its Associated Enterprises (AEs). The Assessing Officer (AO) proposed an adjustment of Rs. 8,32,83,536/- for GIS and GSA services based on the Transfer Pricing Officer's (TPO) findings.

What were the issues?

Whether the transfer pricing adjustment for GIS and GSA services was correctly determined, and if the matter should be remanded for fresh benchmarking.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 144C

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Cases cited in this judgment(2)Show list

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

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Shri Ajit Jain, Ld. A.R, Shri Karnik Kansara, Ld. A.R, Ms. Neha Rai, Ld. A.R, Ms. Sakshi Chimanani, Ld. A.R
For Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Hearing: 22.08.2025Pronounced: 19.11.2025

Per : Narender Kumar Choudhry, Judicial Member: This appeal has been preferred by the Assessee against the order dated 15.05.2023, impugned herein, passed by the Ld. Commissioner of Income Tax (Dispute Resolution Panel-1) (in short Ld. Commissioner) u/s 144C(5) of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2021-22. 2 M/s. Lintas Indi

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