PAR FORMULATIONS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

ITA 1009/CHNY/2017Status: DisposedITAT Chennai23 January 2026AY 2012-13Bench: SHRI ABY T. VARKEY (Judicial Member), MS. PADMAVATHY.S (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the TPO made the upward transfer pricing adjustment based on an incorrect understanding of facts and without proper independent benchmarking. Therefore, the issue was remitted back to the TPO for fresh consideration.

What were the facts?

The assessee transferred intangibles to its affiliate, PAR USA, for a consideration. The Assessing Officer (AO) and Transfer Pricing Officer (TPO) made a significant transfer pricing adjustment, rejecting the assessee's valuation. The Dispute Resolution Panel (DRP) confirmed the adjustment.

What were the issues?

Whether the transfer pricing adjustment made by the TPO for the transfer of intangibles was correctly calculated and substantiated, and whether the assessee's valuation method was appropriate.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 92A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

Hearing: 08.01.2026Pronounced: 23.01.2026

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the final order of the assessment passed by Dy. Commissioner of Income Tax, Company Circle-1 (in short "AO") passed u/s. 143(3) r.w.s 144C of the Income Tax Act, 1961 ( in short "the Act") dated 15.02.2017 for Assessment Year (AY) 2012-13. The grounds of appeal raised by the assessee are as under:

“1. That the order of learned Deputy C

The order continues below.

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