TOLL GLOBAL FORWARDING (INDIA) PRIVATE LIMITED ,GURGAON vs. ACIT, NEW DELHI

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ITITA 43/DEL/2025Status: DisposedITAT Delhi19 June 2026AY 2022-2321 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the five comparable companies identified by the TPO/DRP – Gateway Distriparks Limited, Navkar Corporation Ltd., Sequel Logistics Pvt. Ltd., Unique Expeditors Private Limited, and Shree Vasu Logistics Ltd. – are not valid comparables for the assessee. The reasoning was that these companies own significant transportation fleets, making them functionally dissimilar to the assessee, which is an intermediary that does not own any transportation assets. Consequently, the action of the TPO/DRP and AO in including these comparables and making the related adjustment of Rs. 4,26,00,557/- (part of the total Rs. 4,62,86,002/-) was set aside. Grounds of Appeal No. 1 to 4 were accepted. Regarding the addition of Rs. 36,85,445/- on account of interest on outstanding receivables, the Tribunal, by respectfully following the jurisdictional precedent in the assessee's own case for AY 2015-16 and the decision in AVL India (P.) Ltd. (supra), held that payables and receivables should be netted off. If payables exceed receivables, no addition is warranted against trade receivables. Therefore, the addition was deemed illegal and set aside. The AO/TPO was directed to re-compute the interest chargeable on outstanding net receivables as per law. Ground of appeal No. 5 was allowed. Grounds of appeal Nos. 6 and 7, being consequential, were left open.

What were the facts?

The assessee, Toll Global Forwarding (India) Private Limited, filed an appeal against the final assessment order dated October 17, 2025, passed by the Assessment Unit for Assessment Year 2022-23. The assessee, engaged in freight forwarding, declared an income of Rs. 5,07,76,031/- on a turnover of Rs. 476,38,39,950/-. The case was selected for scrutiny, leading to a reference to the Transfer Pricing Officer (TPO). The TPO initially made an adjustment of Rs. 32,01,23,802/-, which was later revised to Rs. 4,62,86,002/- after the Dispute Resolution Panel (DRP) issued directions. This revised adjustment, comprising Rs. 4,26,00,557/- for freight and operational costs and Rs. 36,85,445/- for interest on receivables, was incorporated into the final assessment order, increasing the total income to Rs. 9,70,62,030/-.

What were the issues?

1. Whether the addition of INR 4,62,86,002/- to the total income is legally sustainable, particularly concerning the selection of comparable companies for determining arm's length price (ALP) for international transactions under Section 92CA of the Act? 2. Whether the addition of Rs. 36,85,445/- on account of notional interest on outstanding receivables from Associated Enterprises (AEs) is valid, considering the netting off of payables and receivables and the interpretation of 'international transaction' under Section 92B of the Act? Assessee's Contentions: - The assessee argued that several comparable companies, including Gateway Distriparks Limited, Navkar Corporation Limited, Sequel Logistics Pvt. Ltd., Unique Expeditors Private Limited, and Shree Vasu Logistics Ltd., are functionally dissimilar because they own significant transportation fleets, whereas the assessee is purely an intermediary without such assets. They also contended that their own search strategy and comparables were rejected unfairly. - Regarding interest on receivables, the assessee relied on their own case for AY 2015-16 and the decision in AVL India (P.) Ltd. v. DCIT, [2017] 88 taxmann.com 11 (Delhi - Trib.), arguing that interest should be computed after netting off payables and receivables, and that outstanding receivables do not constitute a separate international transaction if working capital adjustments are considered at arm's length, citing Kusum Healthcare and PCIT, Delhi v. Qualcomm India Pvt Ltd. Revenue's Contentions: - The revenue, through the CIT(DR), relied on the impugned orders.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 144C(13),Section 144B,Section 92B,Section 270A,Section 274,Section 153

AI-generated summary — verify with the full judgment below

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

Before: SHRI S. RIFAUR RAHMAN & SHRI VIMAL KUMAR

For Appellant: Shri Arun Bhadauria, Advocate
For Respondent: Ms. Shaveta Nakra Datta, CIT(DR)
Hearing: 12.05.2026Pronounced: 19.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”, NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER IT(IT)A No. 43/Del/2025, Assessment Year: 2022-23 Toll Global Forwarding Vs. Assessment Unit, (India) Private Limited, Income-tax Department, Gurgaon National Faceless Unit No. 604, Assessment Centre Signature Tower, Gurgaon H.O., Gurgaon, Haryana, India 122 001 �थायीलेखासं./जीआइआरसं./PAN/GIR No: AACCD1028Q Appellant .. Respondent Appellant by : Shri Arun Bhadauria, Advocate Respondent by : Ms. Shaveta Nakra Datta, CIT(DR) Date of Hearing 12.05.2026 Date of Pronouncement 19.06.2026

O R D E R PER VIMAL KUMAR, JM: The appeal filed by the assessee is against final assessment order dated 17th October, 2025 of the ld. Assessing Officer/ Assessment Unit (hereinafter referred to as “Ld. AO”) u/s 143(3) r.w.s. 144C(13) r.w.s.

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144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for Assessment Year (A.Y.) 2022-23. 2. Brief facts of case are that the assessee filed return of income on 24.11.2022 declaring income of Rs. 5,07,76,031/-. The assessee engaged in the business of rendering freight forwarding services to customers in India. During the year under consideration the assessee shown total turnover of Rs. 476,38,39,950/- on which net profit of Rs. 15,03,16,105/- was declared.

2.1 The case was selected for scrutiny under CASS for following issues:

(i) International related party transactions in services ad intangibles

(ii) Business Purchases

(iii) Refund Claim

(iv) International related party transactions in service

2.2 Notice u/s 143(2) of the Act dated 01.06.2023 and notices u/s 142(1) of the Act dated 22.11.2023 and 08.11.2024 were issued. The assessee submitted submissions/ details and explanation.

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2.3 A reference u/s 92CA(1) of the Act for the computation of Arm’s length price in relation to international transactions was made. Ld. TPO passed order u/s 92CA(3) of the Act dated 25.01.2025 making an adjustment of Rs. 32,01,23,802/- on account of international transaction of assessee.

2.4 Draft Assessment Order dated 24.02.2025 was passed.

2.5 The assessee filed objections against draft assessment order before Dispute Resolution Penal. Hon’ble DRP vide order dated 04.09.2025 issued certain directions to TPO with regard to order passed u/s 92CA(3) of the Act.

2.6 The TPO passed order giving effect dated 29.09.2025 and revised TP adjustment of Rs 32,01,23,802/- to Rs. 4,62,86,002/- in respect of taxpayer’s transaction. The relevant portion of TPO give effect order is as under:

S. No. Particulars Amount(Rs.) 1. Freight and other 4,26,00,557 operational revenue/ Freight and other

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operational cost 2. Interest on Receivables 36,85,445 Total 4,62,86,002

2.7 On considering order giving effects passed by TPO dated 29.09.2025, Ld. AO passed final assessment order dated 17.10.2025 making final computation of income as under:

Sl. No. Description Amount(in INR) 1. Income as per return of 5,07,76,031/- Income filed 2. Income as computed u/s -------- 143(1)(a) 3. Variation in respect of issue 4,62,86,002/- of upward adjustment made by the TPO 4. Total income determined as 9,70,62,033/- per the above proposal 5. Total assessed income 9,70,62,030/- (rounded off)

3.

Being aggrieved, the assessee preferred present appeal on following grounds: -

“1. erred in law and on facts, by making total disallowances/additions of INR 4,62,86,002 to the total income filed by the Appellant.

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2.

erred in considering the following functionally dissimilar companies as comparable to the Appellant for determining the arm's length price for the impugned transactions:

 CJ Darcil Logistics Limited  Freight Systems (India) Private Limited  Shree Vasu Logistics Limited  Unique Speditorer Private Limited  Malabar Coast Marine Services Private Limited  Navkar Corporation Limited  Gateway Distriparks Limited  Sequel Logistics Private Limited 3. erred in rejecting the search strategy and comparable companies submitted by the Appellant during the TP assessment proceedings. 4. erred in the computation of the proposed TP adjustment for impugned transactions by aggregating both revenue and cost side transactions while calculating proportionate adjustment. 5. erred on facts and in law in making an adjustment on account of notional interest on outstanding receivables from Associated Enterprises ("AEs") by characterizing them as loans advanced to them. 6. erred in proposing initiation of penalty proceedings under section 274 read with section ("r.w.s.") 270A of the Act. 7. erred in not appreciating that the time limit prescribed under section 153 of the Act is the outer limit for passing the final assessment order and hence not passing the final assessment order under section 143(3) r.w.s. 144C(13) of the Act by the permissible time limit i.e., 31 March 2025.” 4. Ld. Authorized Representative (“AR”) for appellant/assessee submitted

that the Appellant is a freight forwarding company which only acts as an

intermediary, and the consignments are transported by air/ship/road

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through aircraft or a vessel or a vehicle owned by third parties (such as airlines or shipping lines) and not by the Assessee or its AEs. Thus, the Assessee has no transportation fleet of its own. (Refer TP report para 1.1.2 pg. 36 of 1'B para 6.2.1 pg. 28-29 of PB and para 6.22 pg. 30 of IB. asset schedule a pg 87 of PR which also clearly shows Assessee has no vehicles)

4.1 The following 5 comparables in the freight forwarding segment are invalid comparables, as despite the Appellant being a freight forwarding intermediary with no transportation assets, the following comparables are included by DRP/AO which own significant transportation fleets Once the said 5 comparables are excluded, the margin of Appellant would be at arm's length.

a. Gateway Distriparks Limited (GDL)

(i) TPO’s findings- for Inclusion (Pg.184-185 of Appeal set)- are: -

"On perusal of the website of the company the Gateway Distriparks Limited is an Indian logistics company based in Mumbai with three business verticals. Container Freight Stations, Inland Container Depots with roid

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movement and Cold Chain Storage & Logistics, It is very much clear from the above, that the company has providing similar services as the assessee's. Therefore, this comparable is still a valid comparable and retained in the final list of comparables.”

(ii) DRP’s direction upheld the inclusion.

(iii) Appellant's contention – is that the comparable owns significant fleet of transportation and therefore, not valid comparables.

Largest private container train operator in India owning transportation fleet and transportation related machines of INR 500 crore (gross) including more than 500 trailers.

(Annual report starts a pg.173 of PB, profile showing the significant assets it owns a pg.174. fleet of vehicles and other transportation related equipment amounting to 500 cr. visible a pg.278-279, details of warehouses a pg.236)

b. Navkar Corporation Ltd.

(i) TPO’s Findings -for Inclusion (Pg. 187-188 of Appeal set)- are

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As per the annual report of the compan a We are amongst leading Container Freight" Stations (CFSs) operators with a capacity of 535,500TEUs (Twenty-foot Equivalent Unit) per annum spread across three facilities Ajivali CFSI, Ajivali CFS II, Somathane CFS III and Tumb ICD with a capacity of 4,74,000 TEUs.” It is clear here that the company is providing logistic services to the customer.

(ii) DRP’s direction

The DRP upheld the inclusion with the following observations: [refer pg. 34 of the Appeal set]

“The Panel is of the view that as comparability requires broad similarity of FAR and as exact comparables are an impossibility, this is a suitable comparable.”

(iii) Appellant's contention – are that the comparable owns significant fleet of transportation and therefore, not valid comparables.

Owns transportation vehicles amounting to more than INR 254.67 crore (gross)

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Annual report starts @pg 446 of PB, vehicles amounting to around INR 255 and railway sidings amounting to around INR 290@ pg. 510-511; details of warehouses @ pg 448)

c. Sequel Logistics Pvt. Ltd.

(i) TPO’s Findings –for Inclusion (Pg. 189-190 of Appeal set)-are

On perusal of the annual report of the company, it is revealed that the company is providing logistic and freight services to its customer. The Description of product or service category in annual financial statement is freight services.

On a closer look, it is seen that the objections of the assessee in this context are not acceptable, as the company is functionally very similar to the assessee. Assessee and this company, both are engaged in providing similar services. Under TNMM the standards of comparability are relatively relaxed and only broad similarity of functions is required.

Therefore, this comparable is still a valid comparable and retained in the final list of comparable.

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(ii) DRP’s direction

The DRP upheld the inclusion with the following observations: [refer pg. 35 of the Appeal set)

“The Panel is of the view that as comparability requires broad similarity of FAR and as exact comparables are an impossibility, this is a suitable comparable.”

(iii) Appellant's contention – are that the comparable owns significant fleet of transportation and therefore, not valid comparables.

Own vehicles of around 40 crore @ pg. 586-587 of PB and plant & equipment of INR 12 crore @ 583-584 of PB

d. Unique Expeditors Private Limited

(i) TPO’s Findings –for Inclusion (Pg. 181-182 of Appeal Set)- are

On perusal of the website of the company, it revealed that M/s Unique Speditorer Pvt. Ltd. (formerly called M/s Unique Forwarders), a Gujarat based company, was founded by Mr. Pravin. M. Nagda with a vision to make moves, smooth in the field of Clearing, Forwarding. Shipping.

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Consolidation, Transportation, Warehousing and other Logistic Services. The company has similar business of the assessee's.

On a closer look, it is seen that the objections of the assessee in this context are not acceptable, as the company is functionally very similar to the assessee. Assessee and this company, both are engaged in providing similar services. Under TNMM the standards of comparability are relatively relaxed and only broad similarity of functions is required. Therefore, argument of the assessee is not acceptable and this company is a good comparable.

(ii) DRP’s direction

The DRP upheld the inclusion with the following observations: [refer pg. 29 of the Appeal set]

“The Panel is of the view that as comparability requires broad similarity of FAR and as exact comparables are an impossibility, this is a suitable comparable.”

(iii) Appellant's contention – are that the comparable owns significant fleet of transportation and therefore, not valid comparables.

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Owns fleet of vehicles of more than INR 18 crores (gross) @ pg. 675 of PB

e. Shree Vasu Logistics Ltd. (i) TPO’s Findings –for Inclusion (Pg. 180-181 of Appeal set)- are

As per the annual report of the company Shree Vasu Logistics Limited is a leading ..logistics” and ..Carrying & Forwarding Agent (C&FA)” company in central Indian and expanding its wing to major parts of Eastern and Southern East Part of India. The Company began its journey as C & F Agent in the year 2007 and now providing all types of supporting services required in Logistics sector.

It is very much clear from the above, that the company has providing similar services as the assessee’s. Therefore, this comparable is still a valid comparable and retained in the final list of comparables.

(ii) DRP’s direction

The DRP upheld the inclusion with the following observations: [refer pg. 28 29 of the Appeal Set]

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“The Panel is of the view that as comparability requires broad similarly of FAR and as exact comparables are an impossibility, this is a suitable comparable.

Further, the assessee has not demonstrated how functional similarity between itself and the comparables is offected by the comparable’s ownership of assets. The contention therefore is not tenable”.

(iii) Appellant's contention – are that the comparable owns significant fleet of transportation and therefore, not valid comparables.

Provides onwards transportation services with self-owned fleet amounting to more than INR 5 crore @pg. 756 of PB, warehouses owned by the company @ pg. 730 of PB.

4.2 Hon'ble jurisdictional bench in IAS Forwarding Worldwide (P.) Ltd. v. DCIT, IT Appeal Nos. 2484 (Delhi) of 2014 & 1687 (Delhi) of 201 (relevant para 17-20 @pg.856-857 of PB) held that such cargo companies owning significant fleet of transportation are not valid comparable for an intermediary company like assessee which does not own any fleet of transportation.

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4.3 The aforesaid action of the DRP/AO is in contravention earlier DRP directions in Appellant own case in AY 2015-16 and AY 2021-22, wherein the Ld. DRP had directed the TPO to exclude comparables which own significant assets such as transportation fleet, warehouses, etc. Therefore, the impugned action of DRP/AO in present case is against the principle of consistency as there is no change in facts. (DRP directions for AY 2021-22 start at pg.134, para 2.3.1 at pg. 140-141 of PB; DRP directions for AY 2015-16 are at pg.100 and relevant extract is para 3 a pg.117).

5.

Ld. Departmental Representative submitted that the comparables are similar to the profile of assessee.

6.

From appraisal of record in light of aforesaid rival contention, it is crystal clear that comparables Gateway Distriparks Limited (GDL), Navkar Corporation Ltd. Sequal Logistics Pvt. Ltd. Unique Expeditors Private Limited, Shree Vasu Logistics Ltd. as comparables as under:

S. No. Comparables Not valid comparable as they own

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by AO/DRP significant fleet of transportation for the relevant financial year a. Gateway Largest private container train operator in Distriparks India Owning transportation fleet and Limited transportation related machines of INR (GDL) 500 crore (gross) including more than 500 trailers. b. Navkar Owns transportation vehicles amounting to Corporation more than INR 254.67 crore (gross) Ltd. c. Sequal Owns vehicles of 20.84 crore and motor Logistics Pvt. vehicle of 11.73 crore (gross) Ltd. d. Unique Owns fleet of vehicles of more than INR Expeditors 18 crores (gross) Private Limited

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e. Shree Vasu Provides onwards transportation services Logistics Ltd. with self owned fleet amounting to more than INR 5 crore

Whereas the appellant/assessee company is a freight forwarding company which only acts as an intermediary and has no transportation fleet of its own.

6.1 A co-ordinate Bench in JAS Forwarding Worldwide Pvt. Ltd. Vs. DCIT, IT Appeal Nos. 2484 (Delhi) of 2014 & 1687 (Delhi) of 2016 – Delhi ITAT held as follows:

"5. Brief facts of the case shows that the assessee is a freight forwarder as an intermediary and facilitator in cross-border transaction as an agent of the shippers. Assessee would take responsibility for the entire segment depending upon the terms of the contract and understanding with the shippers et cetera illustrative lead depending upon the terms of the contract or understanding, the freight forwarder shall arrange for loading and unloading, transportation, fixing air or shipping lines through which consignment cell be sent and four other ancillary or incidental matters. 20. With respect to exclusion of Sanmar shipping Ltd the assessee has also given similar explanation and also claimed that this company is also claiming deduction u/s 33AC of the act as it has tonnage tax reserve account in its reserves and surplus. We have carefully considered the argument of the assessee and find that this comparable company also owns fleet and

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fleet equipment as well as the vehicles as per is fixed assets listing. Therefore, this comparable company is also deserved to be excluded for the limited reason that it has own fleet for its transportation business."

6.2 In view of above material facts apparent on record by following the judicial precedents, it is held that the five comparable companies i.e. all Gateway Distriparks Limited (GDL), Navkar Corporation Ltd., Sequal Logistics Pvt. Ltd., Unique Expeditors Private Limited and Shree Vasu Logistics Ltd. Owning significant fleet of transportation are not valid comparable for an intermediary company like assessee which does not own any fleet of transportation. Therefore, the action of Ld. TPO/DRP and ld. AO are set aside. Accordingly, Grounds of Appeal No. 1 to 4 are accepted.

Regarding Ground of Appeal No. 5

7.

Ld. Authorized Representative for appellant/assessee submitted that Ld. AO/ DRP erred in making addition of Rs. 36,85,445/- on account of interest on receivables. In assessee’s own case, DRP for A.Y. 2015-16 held that interest can only be computed after netted off against the trade receivables para no. 2.7.6 @ page 164 of paper book.

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7.1 The DRP Order of AY 2015-16 highlighted above squarely covering the issue in Assessee's favour.

7.2 Reliance was placed on the decision of the Hon'ble jurisdictional Bench of this Tribunal in AVL India (P.) Ltd v. DCIT., [2017] 88 taxmann.com 11 (Delhi - Trib.) (para 12-13)- where it was categorically held that both payables and receivables in aggregate need to be seen and if the payables are more than receivables, then no addition is warranted against trade receivables.

7.3 However, the AO/ DRP has not dealt with this aspect at all. The only reason given by the Ld. DRP/AO to treat the interest on outstanding receivable as a separate international transaction is that such outstanding receivables constitute an 'international transaction' under explanation (c) to Section 92B of the Act (pg.50 of the appeal set, para 16.3.12). Without prejudice to the above contention on netting off, even this observation is squarely in teeth of the Hon'ble jurisdictional High Court in Kusum Healthcare, (ITA 6814/Del/2014) [judgement starts at pg.922, relevant pg.924 of PB, para 10-11), where after the considering the said

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Explanation to Section 92B it was held that that once working capital adjusted margin is considered inter alia qua the outstanding receivable and the said margin is found to be at arm's length then no upward adjustment whatsoever is required to be made even if there is a delay in collection of such outstanding receivables. The decision in Kusum Healthcare (supra) has been followed case after case by the Hon'ble jurisdictional High Court such as in PCIT, Delhi v. Qualcomm India Pvt Ltd ITA 586/2023 [judgement starts at pg. 925, relevant para 19-25 @pq.929-931).

8.

Ld. Departmental Representative relied on impugned orders.

9.

From examination of record, it is crystal clear that Ld. TPO passed order giving effect dated 29.09.2025 made an adjustment of Rs. 36,85,445/- on account of interest on receivables.

9.1 However, in appellant’s own case DRP for assessment year 2015-16 held that interest can only be computed after netting off the trade payables with trade receivables para no. 2.7.6 at page No. 164 of Paper Book which is as under:

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“2.7.6 The only dispute with regard to the computation of interest chargeable on the receivables is that the assessee has substantial payables, details of which have been submitted at pages 479 to 509 of the paper book which were also submitted to the TPO. On a without prejudice basis it is submitted that the payables should be netted off with the receivables and interest should be charged on the net receivables. We are in agreement with the assessee on this argument. The AO/TPO is also directed to net off the payables and charge interest on net receivables, entity wise and on transaction-wise basis. The AO/TPO is directed to re-compute the interest chargeable on outstanding net receivables accordingly."

9.2 A co-ordinate Bench in AVL India (P.) Ltd. (supra) held that both payables and receivables aggregate need to be seen and if payables are more than receivables than no receivables is wanted against trade receivables.

9.3 In view of above material facts by respectfully following Jurisdictional precedent, it is held that the addition of Rs.36,85,445/- on account of interest on outstanding receivables being illegal, is set aside and Ld. AO/TPO is directed to re-compute interest chargeable on outstanding net receivables as per law. Accordingly, Ground of appeal No. 5 is allowed.

10.

Grounds of appeal Nos. 6 and 7 being consequential in nature are left open.

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11.

In the result, the appeal filed by the assessee is allowed.

Order pronounced in the open court on 19.06.2026

Sd/- Sd/- (S. RIFAUR RAHMAN) (VIMAL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 19.06.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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