What is VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd. authority for?

The Arm's Length Price for loans advanced to Associate Enterprises must be determined by the rate of interest prevalent in the country where the loan is received or consumed, taking into account the currency of the loan.

Which sections of the Income Tax Act does VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd. come up under?

It is most often cited in judgments turning on Section 143(3), Section 92B, Section 144C(5), Section 144C(13), Section 144B, Section 153.

VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd. (46 SOT 141)

Q: How many judgments cite VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd.?

54 judgments on BharatTax cite VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd. (46 SOT 141), spanning 2016 to 2025.

DCIT, GURGAON vs. OMAXE LIMITED, NEW DELHI

In the result, the appeal filed by the Revenue is dismissed

ITA 2403/DEL/2025[2014]Status: DisposedITAT Delhi24 Oct 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roydcit, Vs. Omaxe Limited, Gurugram. 7, Local Shopping Centre, Kalkaji, New Delhi – 110 016. (Pan : Aaaco0171H) (Appellant) (Respondent) Assessee By : Shri Akshat Jain, Ca Shri Rajat Jain, Ca Revenue By : Ms. Garima Mathur, Sr. Dr Date Of Hearing : 23.09.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Delhi-44 Dated 13.02.2025 For Ay 2014-15 Raising Following Grounds Of Appeal :- “(I) Whether Ld. Cit(A) Has Erred In Allowing Deduction U/S 80Ib (10) Of The Act To The Tune Of Rs.5,22,08,123/- In Respect Of The Profits From Housing Project Which Are Group Housing Scheme Of Multi-Storied Flats In The Projects Namely M/S Royal Residency, Ludhiana? (Ii) Whether Ld. Cit(A) Has Erred In Following The Order Of Ld. Cit(A) - 19 For The Ay 2011-12 Wherein It Was Held That The Aforesaid Group Housing Scheme Is Separately Satisfying The Conditions Laid Down In The Provisions Of 2 Section 80Ib(10) Despite Observing That The Consolidated Approval Of The Local Authority Is For The Entire Project? (Iii) Whether The Decision Of Ld. Cit(A) Does Not Suffer From The Vice Of Perversity? (Iv) Whether Ld. Cit(A) Has Erred In Law & On Facts By Determining The Credit Spread At 500 Basis Points, Relying Upon The Guidelines Issued By Reserve Bank Of India For External Commercial Borrowing? (V) Whether Ld. Cit(A) Has Erred In Law & On Facts By Ignoring The Judgment Of Hon'Ble High Court?”

For Appellant: Shri Akshat Jain, CAFor Respondent: Ms. Garima Mathur, Sr. DR

Section 80I

…ssue I rely on various judicial pronouncements reported as under:  Siva Industries and Holdings Ltd. vs ACIT [ITA No. 2148/Mds/2148]  Tata Autocomp Systems Ltd vs ACIT [ITA No. 7354/Mum/2011]  Four Soft Ltd. vs DICT 142 TTJ 338  DCIT vs Tech Mahindra Ltd [46 SOT 141 Mum]  Tricorn India Ltd. vs ITO [ITA No. 332/Mu m/2014]  Aurino Solutions Ltd [ita no. 7872/Mum/2011]  Hinduja Global Solutions Ltd vs ACIT [ITA No. 254/Mum/2013]  Cotton Natural India Private Limited [TS -304-lTAT-201(DEL)-TP] The decision in the case of cotton natural India private Limited has been affirmed by Hon’ble High Court of Delhi rep…

BRIGHTCOM GROUP LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1747/HYD/2019[2015-16]Status: DisposedITAT Hyderabad10 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Dr. Narendra Kumar Naik

Section 115JSection 143(2)Section 143(3)Section 144C(5)Section 14ASection 37Section 92C

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

SIGNODE INDIA LIMITED,HYDERABAD vs. ACIT., CIRCLE 3(1), HYDERABAD

In the result, appeal of the assessee is partly allowed for statistical

ITA 1376/HYD/2024[2021-22]Status: DisposedITAT Hyderabad25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri H. Srinivasulu, C.AFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

…24 17 “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

IVY SOFTWARE DEVELOPMENT SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2(1), HYDERABAD

In the result, the ground no

ITA 73/HYD/2022[2017-18]Status: DisposedITAT Hyderabad16 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(2)Section 143(3)Section 144C(5)

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate IT(TP)A No.73/Hyd/2022 28 Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred a…

DSM SHARED SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 501/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 43B

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

SHAKTI HORMANN PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

ITA 452/HYD/2022[2018-19]Status: DisposedITAT Hyderabad21 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna, CIT-DR

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

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad Before Shri Vijay Pal Rao, Vice President and Shri Manjunatha G., Accountant Member आ.अपी.सं /ITA-TP No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner of Limited Income Tax Hyderabad Circle-3(1) [PAN : AADCS4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee by: Shri P.Murali Mohan Rao, AR रधजस् व द्वधरध/Revenue by: Shri B.Bala Krishna, CIT-DR सुिवधई की तधरीख/Date of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Dat…

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 92B

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 2130/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 92B

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

HARSCO INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 2(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1041/HYD/2024[2021-22]Status: DisposedITAT Hyderabad06 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1041/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Harsco India (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 2(1) Pan:Aacch0555L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Suvibha Nolka राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 08/01/2025 घोषणा की तारीख/Pronouncement: 06/03/2025 आदेश/Order

For Appellant: CA Suvibha NolkaFor Respondent: : Shri B Bala Krishna, CIT(DR)

Section 143(3)Section 144C(5)

…under: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

ACIT CENTRAL CIRCLE-29, NEW DELHI vs. OMAXE LTD. , NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 5064/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Jul 2023AY 2011-12

Section 250(6)Section 4Section 801B(10)Section 80I

…sue I rely on various judicial pronouncements reported as under: " Siva Industries and Holdings Ltd. vs ACIT [ITA No. 2148/Mds/2148] " Tata Autocomp Systems Ltd vs ACIT [ITA No. 7354/Mum/2011] " Four Soft Ltd. vs DICT 142 TTJ 338 " DCIT vs Tech Mahindra Ltd [46 SOT 141 Mum] " Tricorn India Ltd. vs ITO [ITA No. 332/Mu m/2014] " Aurino Solutions Ltd [ita no. 7872/Mum/2011] " Hinduja Global Solutions Ltd vs ACIT [ITA No. 254/Mum/2013] " Cotton Natural India Private Limited [TS -304-lTAT-201(DEL)-TP] The decision in the case of cotton natural India private Limited has been affirmed by Hon’ble High Court of Delhi rep…

OMAXE LIMITED,NEW DELHI vs. DCIT CENTRAL CIRCLE-4, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 4966/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Jul 2023AY 2011-12

Section 250(6)Section 4Section 801B(10)Section 80I

…sue I rely on various judicial pronouncements reported as under: " Siva Industries and Holdings Ltd. vs ACIT [ITA No. 2148/Mds/2148] " Tata Autocomp Systems Ltd vs ACIT [ITA No. 7354/Mum/2011] " Four Soft Ltd. vs DICT 142 TTJ 338 " DCIT vs Tech Mahindra Ltd [46 SOT 141 Mum] " Tricorn India Ltd. vs ITO [ITA No. 332/Mu m/2014] " Aurino Solutions Ltd [ita no. 7872/Mum/2011] " Hinduja Global Solutions Ltd vs ACIT [ITA No. 254/Mum/2013] " Cotton Natural India Private Limited [TS -304-lTAT-201(DEL)-TP] The decision in the case of cotton natural India private Limited has been affirmed by Hon’ble High Court of Delhi rep…