ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE1(1), CHENNAI vs. M S. JOYSON ANAND ABHISHEK SAFTEY SYSTEMS PVT LTD, KANCHEEPURAM

ITA 2121/CHNY/2024Status: DisposedITAT Chennai16 January 2026AY 2009-10Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(A) did not blindly accept the CUP method, applying it only where documentation was adequate and using TNMM with the TPO's comparables for the rest. The capacity utilization adjustment was considered valid as it reflected actual differences and was supported by judicial precedents. The Tribunal found no violation of Rule 46A.

What were the facts?

The revenue appealed against the relief granted by the CIT(A) on transfer pricing issues for AY 2009-10. The assessee company, engaged in manufacturing automotive safety products, had international transactions with its Associated Enterprises. The TPO rejected the assessee's benchmarking and adopted TNMM, proposing an adjustment. The CIT(A) granted partial relief by accepting CUP for documented transactions and TNMM for others, and allowing capacity utilization adjustment.

What were the issues?

Whether the CIT(A) erred in accepting the CUP method for some transactions and TNMM for others, and in allowing capacity utilization adjustment, while the revenue alleged violation of Rule 46A.

Which sections of the Income-tax Act were involved?

Rule 10B(1)(e)(iii), Rule 46A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S.R.RAGHUNATHA

Hearing: 21.10.2025Pronounced: 16.01.2026

PER MANU KUMAR GIRI, JM:

Captioned appeal by the revenue and Cross objection by the assessee arise out of the order dated 24.05.2024 passed by the learned

Commissioner of Income Tax (Appeals) [“CIT(A)”], Chennai, for Assessment Year 2009-10. The Revenue is in appeal against the relief & CO No.1/Chny/2025 M/s. M.S. Joyson Anand Abhishek- Safety

The order continues below.

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