KRONOS SOLUTIONS INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”, NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER IT (TP)A No. 4/Del/2026, Assessment Year: 2022-23 Kronos Solutions India Vs. Deputy Commissioner of Private Limited Income Tax, Office No. 243, C-09, Circle 13(1), 2F Regus Elegance, CR Building, Jasola District Centre, New Delhi Old Mathura Road, New Delhi-110025 �थायीलेखासं./जीआइआरसं./PAN/GIR No: AACCD4922B Appellant .. Respondent

Stay Application No. 46/Del/2026 (Arising out of IT (TP)A No. 4/Del/2026), Assessment Year: 2022-23

Kronos Solutions India Vs. Deputy Commissioner of Private Limited Income Tax, Office No. 243, C-09, Circle 13(1), 2F Regus Elegance, CR Building, Jasola District Centre, New Delhi Old Mathura Road, New Delhi-110025 �थायीलेखासं./जीआइआरसं./PAN/GIR No: AACCD4922B Applicant .. Respondent

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Appellant by : Sh. Ajit Jain, CA Sh. Akhil Goel, CA

Respondent by : Shri S.K.Jadhav, CIT-DR

Date of Hearing 26.05.2026 Date of Pronouncement 15.07.2026

O R D E R PER VIMAL KUMAR, JM: The appeal filed by the assessee and Stay Application are against final assessment order dated 11.12.2025 of the ld. Assessing Officer/ Assessment Unit u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for Assessment year (‘AY’) 2022-23. 2. Brief facts of the case are that the appellant/ assesse company filed return of income u/s 139(1) of the Act on 30.11.2022 at a total income of Rs. 1,27,08,39,628/-. The ITR was processed by the CPC u/s 143(1) of the Act on 16.03.2023 at the total income of Rs. 1,42,63,97,960/- making addition of Rs. 15,55,58,335/- to returned income under the head ‘Any other item or items of addition under section 28 to 44DB’.

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2.1 The case of assesse was selected for compulsory scrutiny under CASS for complete scrutiny for examination/verification of following issues:-

i. Large value of international transactions in services in comparison to Revenue from Sale of Services shown in ITR and low profitability (T.P. Risk Parameter) ii. Non-compliance to Income Computation & Disclosure Standards iii. International transactions in services in comparison to revenue from Sale of Services for ITES and low profitability (T.P.Risk Parameter) iv. Addition of assets during the year in the block of assets where rate of depreciation claimed is 40% or higher.” 2.2 Notice u/s 143(2) of the Act and intimation letter dated 01.06.2023 were issued. Notices u/s 142(1) of the Act dated 16.01.2024, 13.05.2024 and letters dated 25.07.2024, 02.08.2024 and notice u/s 142(1) of the Act dated 27.01.2025 and show cause notice dated 03.02.2025 was issued. The assesse made replies.

2.3 The assesse company was engaged in providing software development and related services during the year. The company was also engaged in provision of back-office support services during the period. The case under CASS was also involved TP risk parameters. Therefore, the case was referred to the TPO u/s 92CA(a) of the Act after obtaining

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necessary approval from the competent authority. The Transfer Pricing Officer (TPO) vide order dated 24.01.2025 u/s 92CA(3) of the Act made upward adjustments to the Arm’s Length Price of the transactions as reported by assesse in Form 3CEB. The summary of adjustment proposed by TPO are as under:

S.No. Nature of international Adjustment(Rs.) transaction 1. Provision of Software 44,70,94,226.00 development services s 2. Outstanding receivable 1,53,50,626 Total 46,24,44,852

2.4 A show cause notice dated 03.02.2025 proposing addition of Rs. 46,24,44,852/- to its total income on account of transfer pricing issue was proposed. The assessee filed reply to show cause notice on 10.02.2025.

2.5 Draft assessment order u/s 144C(1) of the Act dated 17.02.2025 proposing adjustment of Rs. 46,24,44,852/- to be made to the total income of assesse was passed. Against draft assessment order u/s 144C(1) of the Act dated 17.02.2025, the assesse filed certain objections before Hon’ble Dispute Resolution Panel (DRP) to new Delhi on 19.03.2025.

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Hon’ble regular DRP-2, New Delhi passed its order u/s 144C(5) of the

Act on 27.11.2025.

2.6 On completion of proceedings, ld. Assessing Officer vide final assessment order dated 11.12.2025 made an addition of Rs.

35,71,95,576/- on account of ALP of the international transactions.

following grounds:

“1. That on the facts and circumstances of the case and in law, the order passed by the Ld. AO under Section 143(3) read with section 144C (13) of the Act is bad in law and liable to be quashed to the extent it confirms the additions/ disallowances made in the assessment order. 2. That on facts and circumstances of the case and in law, the Ld. AO/Ld. TPO/ Ld. DRP have erred in not considering the segmented results submitted by the Appellant and aggregating international transaction pertaining to "Provision of back-office support services" and "Provision of software development services" ("SDS"). 3. The Ld. AO/ Ld. TPO/Ld. DRP erred in enhancing the income of the Appellant by INR 341,844,950/- pertaining to provision of software development services to its Associated Enterprise ("AE") by stating that it does not satisfy the arm's length principle envisaged under the Act and in doing so, have grossly erred in: 3.1. rejecting the arm's length price ("ALP") as determined by the Appellant in the TP documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ("Rules").

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3.2. not sharing the search strategy with the Appellant which was applied by the Ld. TPO for the purpose of benchmarking instant transaction. 3.3. conducting a fresh comparability analysis based on the application of erroneous additional/revised filters in determining the ALP for the Appellant and rejecting the filters applied by the Appellant in its TP documentation. 3.4. inclusion of certain companies during the year under consideration which were already rejected by Hon'ble Dispute Resolution Panel ("DRP") in previous years in Appellant's own case. 3.5. inclusion of functionally dissimilar companies that are full-fledged risk-taking entrepreneurs, high profit-making companies, diversified operations with no segmental accounts, companies with high turnover or which are failing certain filters applied by the Ld. TPO. 3.6. exclusion of additional functionally similar companies additionally proposed by the Appellant. 3.7. committing factual/ computational errors while calculating the operating margins of companies selected as comparable in the TP order. 3.8. not considering the working capital adjusted margins submitted by the Appellant and considering erroneous margins and not sharing the computation of the working capital adjusted margins in the order giving effect post DRP Directions; and 3.9. disregarding judicial pronouncements in India while undertaking the TP adjustment. 4. That the Ld. AO/Ld. TPO erred in enhancing the income of the Appellant by INR 1,53,50,626 as notional interest on alleged international transaction of delay in collection of trade receivables from the AEs. In doing so, the Ld. AO/Ld. TPO have grossly erred in: 4.1. re-characterizing overdue receivable amount as a deemed loan and treating it as a separate international transaction. 4.2. arbitrarily determining the arm's length price of the alleged international transaction of overdue receivables from AEs without placing on record any comparable uncontrolled transaction and instead

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imputing interest at a rate equivalent to 6-month LIBOR plus 425 basis points. 4.3. disregarding the various judicial pronouncements in India while proceeding to enhance the income of the Appellant including the order passed by the Hon'ble Delhi High Court in the case of Kusum Healthcare Pvt. Ltd. [ITA No. 765/2016]; and 4.4. disregarding the credit period of 90 days agreed under inter- company agreement with AE. 5.That the Ld. AO has erred in charging interest under section 234A, 234B, 234C and 234D of the Act. 6. That the Ld. AO also erred in proposing to initiate penalty proceedings under section 270A of the Act mechanically on the additions made.” 4. Ld. Authorized Representative for appellant/assessee submitted that Ground of Appeal No. 1 is general in nature. Grounds of Appeal Nos. 2 and 3 are regarding Transfer Pricing issues pertaining to provision of back-office support services and provision of software development services (SDS). Ground of Appeal No. 4 is regarding issue of notional interest on alleged international transaction of delay in collection of trade receivables from AEs amounting to Rs. 1,53,50,626/-. Ground of Appeal Nos. 5 and 6 are consequential in nature.

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receivables, he submitted return submissions as below: -

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“25. At the outset, it is submitted that the arm's length price determination for the said consequential receivables is subsumed within the arm's length price determination of the principal international transaction itself and therefore no separate arm's length price determination is required once the principal international transactions are tested. In this context, the Appellant places reliance on:  Hon'ble ITAT ruling in the case of Kusum Healthcare Pvt. Ltd (ITA No. 6814/Del/2014) which is also is affirmed by the Hon'ble Delhi High Court ("HC") (ITA NO. 765/2016. The relevant extract from the Hon'ble HC ruling is reproduced below for your Honour's ready reference "..... 11. The Court finds that the entire focus of the AO was on just one AY and the figure of receivables in relation to that AY can hardly reflect a pattern that would justify a TPO concluding that the figure of receivables beyond 180 days constitutes an international transaction by itself. With the Appellant having already factored in the impact of the receivables on the working capital and thereby on their pricing/profitability via vis-vis that of its comparables, any further adjustment only on the basis of the outstanding receivables would have distorted the picture and re-characterized the transaction. This was clearly impermissible in law as explained by this Court in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Delhi)..." (Emphasis supplied) 26. The Hon'ble ITAT in the Appellant's own case for AY 2017-18 appreciated the fact that the principal international transaction of provision of software development services taking into account working capital adjustment has been undertaken on arm's length basis and thus the consequential receivables arising out of the said transaction too satisfies arm's length standard and thus separate arm's length determination is not required. 27. Further, the Appellant relied upon case law of Kusum Health Care (P) Ltd. (ITA No. 765/HC/Del/2016) and following the precedents, Hon'ble ITAT directed the Ld. AO/ TPO to delete the transfer pricing adjustment in this regard. The Appellant would also like to place reliance on the following judicial precedents as well:  The Hon'ble ITAT judgement in case of Bechtel India Pvt. Ltd., the Delhi High Court (ITA 379/2016)  The Hon'ble ITAT judgement in case of BTR Packaging Pvt Ltd in (ITA/1516/Del/2016).

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 The Hon'ble ITAT judgement in case of M/s. Barco Electronic Systems (P.) Ltd.  The Hon'ble ITAT judgement in case of Bertelsmann Marketing Services India Pvt. Ltd. vs. DCIT (ITA No. 6579/Del/2015).  The Hon'ble ITAT judgement in case of Dell International Services India Pvt. Ltd (IT.(T.Ρ.) A. No.308/Bang/2015).  The Hon'ble ITAT judgement in case of M/s. Barco Electronic Systems (P) Ltd. vs. DCIT (ITA No. 1531/Del/2016)  M/s American Express Services India Private Limited vs. DCIT (ITA No. 1982/Del/2015)  Optum Global Solutions (India) Pvt. Ltd. vs. ACIT (ITA No. 6665/Del/2017)  EXL Service.com (India) Pvt Ltd vs. DCIT [TS-412-HC- 2017(DEL)-TP)  iQor India Services Pvt. Ltd vs. DCIT (TS-365-ITAT-2020(DEL)- TP)  DHR Holding India Pvt. Ltd. vs. DCIT (ITA No. 1758/Del/2016)  Redtech Network India Private Limited vs. ACIT (TS-1143-ITAT- 2019(Kol)-TP) Based on the above, the overdue receivables resulting from the above transaction also get benchmarked and do not warrant any further adjustment.” 7. Ld. Departmental Representative submitted that the appellant/assessee provided IT services. Comparables AC technologies Limited and Cybage Software Private Limited are similar to the assessee. Interest on receivables was fairly proposed considering the collection period.

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the business of software services that enables organizations to reduce

costs, increase productivity, improve employee satisfaction, and enhance

the level of service they provide Kronos Solutions is also engaged in

provision of back-office support services ("IT enabled services") which

involves application support services, technical support services and

hosting services. The summary of economic analysis of the international

transactions undertaken by the Company during the financial year ("FY")

2021-22 with its AEs page No. 9 of Paper Book is as below:

S. No. Nature of Method applied Profit level Tested Arm’s international indicator (PLI) Party Length transaction Margin range as per TP Report 1. Provision of TransactionalNet Operating 13.74% 3.81%- software Margin Method profit/operating 18.57% with development (TNMM) cost (OP/OC) median of services. (SDS) 11.03 2 Provision of TNMM OP/OC 17.81% 10.76%- back-office 18.08% with support median of services 16.17% ("ITES) 3 Reimbursement Other Method Not Applicable NA 6,59,06,416 of Rule 10AB (“N.A.”) expenses received

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8.1 During the course of assessment proceedings, the Ld. AO made a reference under section 92CA of the Act to the Learned Transfer Pricing Officer ("Ld. TPO"). Thereafter, in response to the notice issued by the Ld. TPO under section 92CA (2) of the Act, the information and documents (as prescribed under section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ("the Rules")] maintained by the Appellant were submitted to the Ld. TPO.

8.2 The Ld. TPO issued a show-cause notice proposing to reject the SDS and ITeS segments reported by the Appellant and combined both the segments and arrived at the margin of 13.32%. The Ld. TΡΟ rejected the economic analysis undertaken by the Appellant in the TP documentation and instead, the Ld. TPO substituted the results of Appellant's economic analysis with the results of fresh set of comparables selected by applying different quantitative filters.

8.3 Further, Ld. TPO has proposed to recharacterize overdue receivables from the AEs as a deemed loan stating that it constitutes a separate international transaction.

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8.4 The Ld. TPO adopted to reject the SDS and ITeS Segment reported by the Assesee and followed the below approach for benchmarking Appellant's international transaction pertaining to provision of software development services.

The final comparable set adopted in the TP order has been given below

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8.5 The Ld. TPO did not allow working capital adjustment to the Appellant in arriving at the arm's length margin.

8.6 The Ld. TPO made an adjustment on account of notional interest amounting to INR 1,53,50,626 on account of alleged international transaction for delay in collection of trade receivables from the AEs.

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8.7. The Ld. TPO proceeded to pass its order (Refer page no. 524 to 577 of paperbook) dated January 24, 2025, under section 92CA (3), wherein the following TP adjustments were proposed by holding that the Appellant's international transactions do not satisfy the arm's length standard:

8.8 As per order passed by the Ld. TPO, the Ld AO, issued a draft assessment order dated February 17, 2025, after incorporating the above adjustment pertaining to software development service and Outstanding Receivable (Page Nos. 491 to 523 of Paper Book).

8.9 The Appellant filed its objections before the Hon'ble Dispute Resolution Panel ("Hon'ble DRP") (Refer page no. 614 to 713 of paperbook).

8.10 The Hon'ble DRP provided the working capital adjustment and upheld the other contentions vide directions dated November 27, 2025 (Refer page no. 485 to 490 of paperbook), wherein TP adjustment was reduced

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to INR 357,195,576. The final range computed by Ld. TPO/Ld. AO after working capital adjusted margin is as follows:

8.11 Pursuant to the directions passed by the Hon’ble DRP, the Ld. AO issued final assessment order dated December 11, 2025 resulting in adjustment of INR 35,71,95,576 (INR 34,18,44,950 for Software development and INR 1,53,50,626 for outstanding receivable).

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 Fails Export Earning Filter

In this regard, the Appellant would like to bring to your Honor’s kind attention that Odyssey Technologies is failing the export earning filter applied by the ld. TPO. The computation of said filter has been tabulated below:

 Functionally not comparable

Odyssey Technologies is mainly engaged into the Business of Software development with primary focus on information security products built around the Public Key Infrastructure and cryptography. and the related services. It is also engaged in is engaged in Cryptography and Internetworking offers solutions built around Public Key Infrastructure

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(PKI), the framework that brings authentication, privacy, integrity and non-repudiation into the omnipresent world of the Internet.

 Functionally not comparable

Domex is engaged in the business of providing knowledge processing services such as patent analysis. technical editing, deep indexing of scientific and technical research papers etc. Based on above, it can be concluded that Domex is a KPO company and is not functionally comparable to the Appellant.

Hon'ble Mumbai ITAT in the case of Syngenta Services Private Limited (ITA NO.1905/MUM/2022) has clearly stated that:

"Domex: The objection of assessee is that the company is a KPO and not a BPO hence, functionally different. The TPO rejected the same and held that since KPO is part of ITES, the said company is comparable. The assessee has substantiated before us the complex nature of activities carried out by Domex. The said company is also engaged in diversified activities including software development and no segmental reporting of various streams of revenue is available in financial reporting of the company. We further find that the Co-

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ordinate Bench in the case of Katerra Technology Services LLP vs. ACIT (supra) held that Domex is not functionally comparable to company engaged in providing ITES services. The Tribunal further observed that Domex is engaged in diversified activities including software development, KPO and BPO services, hence, functionally dissimilar. Similar view has been expressed in the case of Altair Engineering India (P) Ltd. Vs. ACIT,147 taxmann.com 476 (Bang-Trib). Thus, in facts of the case and in the light of decision referred above, we hold Domex E-Data Pvt. Ltd. is not functionally comparable to assessee and hence, is directed to be excluded from the list of comparables."

 Functionally not comparable

Sasken Technologies is engaged into product engineering and digital transformation providing concept-to-market, chip-to-cognition R&D services in semiconductor, automotive, industrials, smart devices & wearables, enterprise grade devices, satcom, and transportation industries.

 Rejected by Hon'ble DRP for AY 2016-17 and AY 2017-18

Hon'ble DRP in its direction stated that the company has a different profile stating that Sasken is operating in R&D industry catering wide

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range of industries including semiconductor, mobile handsets, smartphones and others.

Cybage is engaged in the diversified business such as:

 Digital Product Engineering.  Provides digital services  Provides ITeS and BPO services  Provides digital product engineering development  Provides architectural services; and etc.

➤ Segmental data not available

Cybage is engaged in diversified businesses, relevant information on segmental detail is not available in the public domain. There is no segmental break-up/information provided in the Annual Report of the Company, specifically pertaining to the software development activities. In the absence of relevant segmental financial information that is

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necessary to accurately analyze the Company's profitability, it is submitted that the Company should be rejected from final set of comparable.

 Rejected by Hon'ble DRP for AY 2017-18

The Hon'ble DRP in its directions stated that Cybage to be included only if the segmental results of the company are available.

8.12 In view of abovesaid material facts it is evident that the Odyssey Technologies Ltd, Domex E-Data Pvt. Ltd., Sasken Technologies Ltd. And Cybage Software Pvt. Ltd. were functionally not comparables. Therefore, aforesaid four comparable are liable to be excluded from final list of comparables. Accordingly, grounds of appeal No. 3.4 and 3.5 challenging inclusion of comparables and ground No. 3.6 challenging exclusion of comparables are allowed.

8.13 The Appellant submitted the final set of comparables (after exclusion of the four comparables) as tabulated below: -

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8.14 From above, it is evident that the detailed working capital computation

in compliance with the directions of the Hon’ble DRP furnished by the

Appellant was incorrectly rejected, and instead Ld. TPO carried out an

erroneous working capital computation. Therefore, the working capital

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adjustment as computed by the Ld. AO/Ld. TPO is set aside, and Ld. TPO is directed to re-compute working capital adjustment as per law. Accordingly, Ground of Appeal No. 3.8 is accepted in above terms.

9.1 The Appellant placed reliance on:

Hon'ble ITAT ruling in the case of Kusum Healthcare Pvt. Ltd (ITA No. 6814/Del/2014) which is also is affirmed by the Hon'ble Delhi High Court ("HC) (ITA NO. 765/2016. The relevant extract from the Hon'ble HC ruling is reproduced below for your Honour's ready reference. "..... 11. The Court finds that the entire focus of the AO was on just one AY and the figure of receivables in relation to that AY can hardly reflect a pattern that would justify a TPO concluding that the figure of receivables beyond 180 days constitutes an international transaction by itself. With the Appellant having already factored in the impact of the receivables on the working capital and thereby on their

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pricing/profitability via vis-vis that of its comparables, any further adjustment only on the basis of the outstanding receivables would have distorted the picture and re-characterized the transaction. This was clearly impermissible in law as explained by this Court in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Delhi)..." (Emphasis supplied)

9.2 The Hon'ble ITAT in the Appellant's own case for AY 2017-18 appreciated the fact that the principal international transaction of provision of software development services taking into account working capital adjustment has been undertaken on arm's length basis and thus the consequential receivables arising out of the said transaction too satisfies arm's length standard and thus separate arm's length determination is not required.

9.3 In light of above facts and judicial precedent, it is held that Ld. AO/TPO erred in making working capital adjustment for interest on outstanding receivables and same are deleted. Accordingly, Ground of Appeal No. 4 is accepted.

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Order pronounced in the open court on 15.07.2026

Sd/- Sd/- (S. RIFAUR RAHMAN) (VIMAL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 15.07.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI