SPECTRIS TECHNOLOGIES PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

ITA 3563/DEL/2014Status: DisposedITAT Delhi17 December 2025AY 2008-0917 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal agreed with the assessee that the business should be treated as two separate segments, consistent with the previous year's ruling. The issue was restored to the TPO for re-verification of benchmarking on a segment-wise basis.

What were the facts?

The assessee argued that its business should be treated as two separate segments (Agency and Marketing Support Services, and Annual Maintenance Services) for transfer pricing analysis. The TPO had aggregated these segments, leading to an adjustment. The assessee pointed to a previous year's ITAT ruling that accepted the two-segment approach.

What were the issues?

Whether the assessee's business segments were correctly identified for transfer pricing analysis, and if the aggregation of segments by the TPO was justified.

Which sections of the Income-tax Act were involved?

Section 92C,Section 92,Section 234B,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH, ‘I’: NEW DELHI

Before: SHRI C.N. PRASAD & SHRI NAVEEN CHANDRA

For Respondent: Ms. Priya Goel, Sr. DR
Hearing: 10.10.2025Pronounced: 17.12.2025

PER C.N. PRASAD, JM, This appeal is filed by the assessee against the order of the Ld.Commissioner of Income Tax (Appeals) -20, New Delhi vide order dated 27.03.2014 for the A.Y. 2008-09. The assessee has raised following grounds :-

1.

That on the facts and circumstances of the case and in law, the order passed by the Ld. Commissioner of Income-tax (Appeals)-XX, New Delhi ("CIT(A)") is bad in law.

2.

That on the facts and circumstances of the case and in law the Ld. CIT(A) erred in upholding the addition of Rs.17,985,243 to the returned income of the Appellant made by the Ld. AO and Ld. TPO by re-computing the arm's length price of the international transactions under section 92 of the Act.

3.

The Ld. CIT(A) erred in facts a

The order continues below.

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