DY.COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

ITA 4907/MUM/2025Status: DisposedITAT Mumbai10 March 2026AY 2011-12Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to exclude Acropetal Technologies Ltd. as a comparable due to low employee cost and significant R&D activities. It also upheld the inclusion of e4e Healthcare Business Services Pvt. Ltd. as a comparable, noting its acceptance in previous assessment years.

What were the facts?

The assessee, BP India Pvt. Ltd., provides business support services to its Associated Enterprises. The Transfer Pricing Officer (TPO) rejected the assessee's comparables and selected its own set. The CIT(A) made certain adjustments regarding the inclusion/exclusion of comparables.

What were the issues?

The primary issues revolved around the selection and exclusion of comparable companies for transfer pricing analysis and the validity of the assessment order due to limitation.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 153

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “K” BENCH MUMBAI

Before: SHRI PAWAN SINGH & SHRI GIRISH AGRAWAL

Hearing: 18.12.2025Pronounced: 10.03.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the Revenue and cross objection filed by the assessee against the order of CIT (A) 55, Mumbai, vide order no. ITBA/APL/S/250/2025-26/1076574916(1), dated 30/05/2025, passed against the assessment order by ACIT - 9(2)(1), Mumbai, u/s. 143(3) r.w.s 144(C)(3)(b) of the Income-tax Act (hereinafter referred to as the “Act”), dated 13.04.2015, for A

The order continues below.

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