TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

ITA 1789/BANG/2024Status: DisposedITAT Bangalore08 January 2026AY 2020-21Bench: us submitted that the assessee does not wish to pursue the issue raised in the captioned ground of appeal. Hence, the impugned ground of appeal is hereby dismissed as not pressed. 6. The issue raised by the assessee through Ground No. 5 of its1 pages
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What did the Tribunal hold?

The Tribunal, following a coordinate bench's decision, held that the remeasurement gain on defined employee benefit plan should be treated as operating. The issue of foreign exchange loss was not pressed by the assessee.

What were the facts?

The assessee treated remeasurement gain on defined employee benefit plan as operating and foreign exchange loss as non-operating. The TPO disagreed, treating the gain as non-operating and the loss as operating. The DRP confirmed the TPO's action.

What were the issues?

Whether remeasurement gain on defined employee benefit plan is operating or non-operating for transfer pricing purposes.

Which sections of the Income-tax Act were involved?

Section 92C

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Income Tax Appellate Tribunal, ‘C’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Darpan Kriplani, CA
For Respondent: Dr. KJ Dhivya, CIT (DR)
Hearing: 09.12.2025Pronounced: 08.01.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the assessment order passed by the AO vide order date 26.07.2024 having DIN ITBA/AST/S143(3)/2024-25/1067079032(1) for the AY 2020-21 pursuant to DRP-2, Bengaluru order dt. 11.06.2024. 2. The Assessee before us has filed revised grounds of appeal vide letter dated 5th March 2025. Through the revised grounds of appeal, the IT(TP)A No.1789/Bang/2024 assessee has raised multiple grounds and sub-grounds under the main ground which are numbered as Ground Nos. 1 to 21. 3. The issues raised by the assessee

The order continues below.

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