D.C.I.T. CIRCLE 3(3), MUMBAI vs. RBS BUSINESS SERVICES P. LTD., MUMBAI

ITA 4467/MUM/2012Status: DisposedITAT Mumbai14 August 2026AY 2007-0830 pages
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What were the facts?

The assessee, engaged in back office support, software services, and KPO, had international transactions with its Associated Enterprises. The Transfer Pricing Officer (TPO) made significant adjustments to the Arm's Length Price (ALP) of these transactions. The Commissioner of Income Tax (Appeals) partly allowed the assessee's appeal, deleting some adjustments but sustaining others.

What did the Tribunal hold?

The Tribunal held that the TPO's determination of ALP at NIL for communication, computer, and professional charges was unsustainable as the assessee had recharged these costs with a markup. The issue of unbilled revenue for Section 10A deduction was remanded to the Assessing Officer for fresh adjudication.

What were the issues?

The key issues were the correctness of the TPO's transfer pricing adjustments for various services and the treatment of unbilled revenue for Section 10A deduction.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 10A,Section 133(6),Section 250,Section 143(3),Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI “I” BENCH: NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Appellant: Shri S.K.Agarwal, CA &, Shri Ajit Jain, AR
For Respondent: Shri Dharm Veer Singh, CIT DR
Hearing: 25.05.2026Pronounced: 14.08.2026

PER MANISH AGARWAL, AM : The captioned cross-appeals are filed by assessee and the Revenue against the order dated 02.04.2012 by Ld. Commissioner of Income

The order continues below.

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