24/7 Customer.Com Pvt Ltd. v. DCIT (

41 SOT 1Income Tax Appellate Tribunal2010#24891 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2026.

Sections most often in play

Section 143(3)Section 144B Section 144C(13)Section 92CA(3)

Judgments citing 24/7 Customer.Com Pvt Ltd. v. DCIT (

Marks and Spencer (India) Private Limited, Gurgaon vs. ACIT, Circle 1(1), Gurgaon

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1937/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Jan 2026AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

…oc manner. Such an approach is unappreciable and struck down by the Jurisdictional Delhi Bench of the Hon’ble ITAT in the case of Mentor Graphics (Noida) Private Limited (2007) 109 ITD 101 and Mumbai bench in the case of Indo American Jewellery Limited (2010) 41 SOT 1. 11. The Appellant would like to submit that the search process adopted by the Ld. TPO suffers from varied flaws as instead of identifying comparable royalty agreements from the database, the Ld. TPO has proceeded to compare royalty rate of the Appellant with the royalty/ sales percentage of the companies (computed from the annual report). The Ld. T…

Deputy Commissioner of Income Tax -14(1)(2), Mumbai vs. Citicorp Services India Limited, Mumbai

In the result, appeal of the Revenue is partly allowed and appeal of the assessee is dismissed

ITA 4609/MUM/2017[2010-11]Status: DisposedITAT Mumbai20 Jul 2021AY 2010-11

Section 143(3)

…se M/s Motorola Solutions India P Ltd Vs ACIT (ITA No ITA No. 5637/Del/2011) and has been further upheld by the ITAT Bangalore in the case of 24/7 Customer.Com Pvt Ltd Vs DCIT (140 ITD 0344), the ITAT Mumbai in the case of DCIT VS Indo American Jewellery Ltd (41 SOT 1) and the ITAT Hyderabad in the case of M/s Deloitte Consulting India P Ltd Vs DCIT (12 taxmann.com 500). 2B) Whether on the facts of the case and in law, the Ld CIT (A) erred in rejecting the quantitative and qualitative filter of related party transactions less than 25% applied by the TPO for selecting the comparables for the purpose of determining…

M/S Obulapuram Mining Company P. Ltd., Bellary vs. DCIT, Bangalore

In the result, the appeal of the assessee is allowed

ITA 545/BANG/2012[2008-09]Status: DisposedITAT Bangalore29 Jul 2016AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri A.K.Garodia, Accounant Member

For Appellant: Shri Mayank Jain, AdvocateFor Respondent: Dr. Sibichen K.Mathew, CIT-III

Section 263Section 92A

…he tax rates were at par with India, or may be more than that; that the assessee's profits were exempt uls1lOB; and that hence, there was no case that the assessee would benefit by shifting profits outside India. 50. In the case of "Indo-American jewellery", 41 SOT 1 (Mum), the Mumbai Bench of the Tribunal found merit in the submissions on behalf of the assessee that since the tax rates were higher in the USA compared with those of India, there would not be any incentive to transfer the profits to a higher tax chargeable region, especially when the company enjoyed deduction u/s 80HHE of the Act. 5l. In" DCIT vs…