JUNIPER NETWORKS SOLUTION INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-13(1), NEW DELHI, NEW DELHI

ITTPA 232/DEL/2026Status: DisposedITAT Delhi31 August 2026AY 2022-234 pages
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What were the facts?

The assessee, Juniper Networks Solution India Private Limited, is in appeal against an order dated 14.01.2026 passed by the AO-NFAC under section 143(3) read with section 144C(13) and 144B of the Income Tax Act, 1961. The original order involved an upward adjustment of Rs. 11,75,72,460/- under section 92CA(4). The assessee subsequently filed a rectification application under section 154 on 13.01.2026. Following this, the AO passed a rectification order dated 27.05.2026, which deleted the transfer pricing adjustment entirely. The appeal before the ITAT was filed for Assessment Year 2022-23.

What did the Tribunal hold?

The Tribunal noted that the grievance of the assessee was settled due to the rectification order passed by the AO, which deleted the transfer pricing adjustment entirely. The Tribunal observed that the Ld. AR had placed on record the rectification order through which the TP adjustment of Rs. 6,32,02,940/- was reduced to Nil. The Ld. AR stated that their grievance ventilated through the grounds of appeal were effectively settled. The Ld. DR also agreed that the grievance of the assessee was settled. Therefore, the grounds of appeal did not survive for adjudication. However, acceding to the request of the Ld. AR, the Tribunal directed the Ld. AO to give effect to the rectification order passed by him. The appeal was partly allowed.

What were the issues?

1. Whether the appeal filed by the assessee survives for adjudication given that the transfer pricing adjustment has been deleted by the AO in a subsequent rectification order? (Question of law and fact) Assessee's contention: The assessee argued that subsequent to the filing of the appeal, the TPO, in response to a rectification application under section 154, passed a Rectification Order dated 27.05.2026. The TPO acknowledged that the assessee's operating margin of -1.74% fell within the arm's length range of working capital adjusted margins (between -1.78% to 0.16%) of comparable companies. Consequently, the TPO held that the international transactions were at arm's length and revised the TP adjustment of INR 6,32,02,940 to Nil, deleting it entirely. The assessee requested the ITAT to direct the Ld. AO to give effect to this Rectification Order, as their grievance was effectively settled. Revenue's contention: The Ld. DR agreed that the grievance of the assessee was settled.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA(4),Section 154

AI-generated summary — verify with the full judgment below

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

Before: MS. KAVITHA RAJAGOPAL & SHRI SANJAY AWASTHI

For Appellant: Shri Anurag Singhal, CA Shri Sandeep Bhalla, CA, Ms. Ariba, AR
For Respondent: Shri Mahesh Kumar, CIT DR
Hearing: 05.08.2026

PER SANJAY AWASTHI, ACCOUNTANT MEMBER:

1.

This appeal arises from order dated 14.01.2026, passed by Ld. AO-NFAC u/s 143(3) read with section 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereafter as “the Act”).

1.

1 In this case, the Ld. AO made an upward adjustment of Rs.11,75,72,460/- u/s 92CA(4) of the Act.

1.

2 It is seen from the record that the assessee filed an application for rectification of the order

The order continues below.

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