DCIT CIRCLE 3 3 1, MUMBAI vs. XORIANT SOLUTIONS PRIVATE LIMITED, MUMBAI

ITA 3673/MUM/2025Status: DisposedITAT Mumbai31 October 2025AY 2018-19Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A)'s analysis of the comparables was not sufficiently detailed and that the filters used by the assessee for TNMM were not discernable. Therefore, the matter was remitted back to the TPO for fresh analysis.

What were the facts?

The Revenue appealed against the CIT(A)'s order which excluded certain companies from the list of comparables used for benchmarking under the TNMM method. The assessee argued for the inclusion of its own comparables from its TPSR, while the TPO had proposed a different set.

What were the issues?

The primary issue was the correctness of the exclusion/inclusion of comparable companies for benchmarking under the TNMM method. The Tribunal also considered the adequacy of the analysis performed by the lower authorities.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

Hearing: 28.10.2025Pronounced: 31.10.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These two appeals filed by the Revenue are against the orders of CIT (A) 58, Mumbai, vide order nos. ITBA/APL/S/250/2024- 25/1074419252(1) and ITBA/APL/S/250/2024-25/1074418247(1), dated 12.03.2025 passed against the assessment orders by NFAC, Delhi, u/s. 143(3) r.w.s 144C(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 23.11.2021 for AY 2018-19 and dated 09.06.2021 for AY 2017-18. 2. Grounds taken by the Revenue are reproduced as under: Xoriant Solutions Pvt. Ltd. AYs

The order continues below.

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