DCIT-13(1)(1), MUMBAI vs. M/S ORACLE FINANCIAL SERVICES SOFTWARE LTD., MUMBAI

ITA 3995/MUM/2019Status: DisposedITAT Mumbai19 February 2026AY 2008-0956 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal followed its earlier decision for AY 2006-07, accepting the assessee's benchmarking approach and treating the assessee as the tested party. The disallowance under Section 14A was also contested.

What were the facts?

The assessee, Oracle Financial Services Software Limited, is in appeal against the CIT(A)'s order for AY 2008-09. The dispute involves disallowance under Section 14A and transfer pricing adjustments related to international transactions with overseas subsidiaries.

What were the issues?

Whether the CIT(A) erred in upholding disallowance under Section 14A and in the transfer pricing adjustment by not accepting the assessee as the tested party. Also, whether training income and telecommunication expenses should be considered for Section 10A deduction.

Which sections of the Income-tax Act were involved?

Section 14A,Section 92C,Section 10A

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Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI GIRISH AGRAWAL

For Appellant: Shri G.C. Srivastava/Shri Sukhsagar Syal, A/Rs
For Respondent: Shri Pankaj Kumar, CIT D/R
Hearing: 27.01.2026Pronounced: 19.02.2026

Per Smt. Beena Pillai, JM: The present cross-appeals arise out of the order dated 01/03/2019 passed by the Ld. CIT(A)-57 (hereinafter referred to as the “Ld. CIT(A”)] for A.Y. 2008-09 on the following grounds of appeal:-

2.

The assessee has raised the following grounds of appeal:- "GROUNDS OF APPEAL The grounds of appeals (including sub-grounds)

The order continues below.

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