ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

ITA 2321/DEL/2022Status: DisposedITAT Delhi10 November 2025AY 2018-1943 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the TPO's rejection of the Resale Price Method (RPM) and adoption of TNMM at the entity level for benchmarking was not fully justified, especially considering the low percentage of international transaction costs. The Tribunal decided to remand the issue back to the AO/TPO for re-benchmarking.

What were the facts?

The assessee, Ecoenergy Insights Ltd., engaged in international transactions including purchase of equipment and availing support services. The TPO proposed adjustments, which were sustained by the DRP. The assessee appealed these adjustments.

What were the issues?

Whether the Resale Price Method (RPM) was the most appropriate method for benchmarking the international transactions, or if TNMM at the entity level was correctly adopted by the TPO. The adequacy of evidence provided by the assessee for the transfer pricing study was also a key issue.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 147,Section 144C(13),Section 144B,Section 143(2),Section 142(1),Section 37

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

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

For Appellant: Shri Nageshwar Rao, Advocate, Shri Parth, Advocate, Shri Pratik Rath, Advocate
For Respondent: Shri S.K. Jadhav, CIT DR
Hearing: 12.08.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

This appeal preferred by the assessees is directed against the assessment order dated 25.07.2022passed by the Assessment Unit, Income Tax Department under section 147 read with section 144C(13) r.w.s. 144B of the Income-tax Act, 1961 (for short ‘the Act”) for AY 2018-19 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act.

2

2.

Brief facts of the case are, assessee revised the return of income for the AY 2018-19 on 29.03.2019 declaring total income of Rs.Nil. The said return of income was selected for scrutiny through CASS. On selection of

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 92CA

All 3,978 judgments and leading authorities on Section 92CA →

Recent GST High Court judgments

Search GST case law →