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“transfer pricing order”

Assessment ProceduresSection 92CASection 92CA358 judgments

The decision most relied on for transfer pricing order is Commissioner of Income Tax v. Roca Bathroom Products (P) ltd. (445 ITR 537), cited in 269 judgments on BharatTax.

Leading authorities on transfer pricing order

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

Kolhapur Canesugar Works Ltd. v. Union of India
2 SCC 536 · 2000 · Reported
117
citing judgments

Section 6 of the General Clauses Act, which preserves rights and liabilities under repealed statutes, does not automatically apply to a mere omission of a statutory provision unless the omitting enactment specifically provides for it, thereby affecting the continuation of pending proceedings.

International Air Transport Association v. DCIT
68 Taxmann.com 246 · 2016 · High Court
38
citing judgments

Failure to follow the procedure laid down in Section 144C(1) of the Income-tax Act, 1961, constitutes a breach of mandatory provisions, rendering the final assessment order void.

Pfizer Healthcare India (P.) Ltd. v. Joint Commissioner of Income-tax
433 ITR 28 · 2021 · High Court
36
citing judgments

A transfer pricing order passed after the expiry of the prescribed limitation period, computed in accordance with Section 153 of the Income-tax Act, 1961, is barred by limitation and liable to be quashed.

Healthcare India Pvt. Ltd. v. JCIT
124 Taxmann.com 536 · 2021 · High Court
18
citing judgments

Assessment orders made beyond the time limits prescribed under Section 153 of the Income-tax Act, considering the specific provisions for transfer pricing assessments, are liable to be quashed.

Mahindra & Mahindra Ltd. v. ACIT
106 ITD 521 · 2006 · ITAT
18
citing judgments

The benchmarking of interest rates on loans advanced to associated enterprises in foreign currency should consider LIBOR, comparing related transactions involving loan advancements and interest charges.

DCIT v. Saint Gobain India (P.) Ltd.
444 ITR 636 · 2022 · High Court
17
citing judgments

An order passed by the TPO is bad in law if it is beyond the limitation period prescribed under section 92CA(3A) read with section 153 of the Act.

Barclays Bank PLC v. ADIT
90 Taxmann.com 378 · 2018 · Reported
17
citing judgments

A transfer pricing officer (TPO) must follow the prescribed method under section 92C for determining the arm's length price. If the TPO fails to do so, the matter cannot be remanded back to the TPO, and the ITAT order should be followed.

Judgments citing transfer pricing order

Shapoorji Pallonji and Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle -3(3)(1), Mumbai

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

risks associated with the transactions, like the credit risk of the AE, currency and country risk etc.) – [Paragraph 7 of the Transfer Pricing Order passed under Section 92CA(3) of the Act] Assessment Year 2012-2013 & 2013-2014 18. We note that in the case of the Assessee ... charged in other international transactions of the Assessee (i.e average of 1.5%, 0.66% and 0.70%) which comes to 0.95% [Paragraph 7 of the Transfer Pricing Order passed under Section 92CA(3) of the Act] Assessment Year 2012-2013 & 2013-2014 since the assessee issuing the performance guarantee was not subjected

Shapoorji Pallonji and Company Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 8(3), Mumbai

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

risks associated with the transactions, like the credit risk of the AE, currency and country risk etc.) – [Paragraph 7 of the Transfer Pricing Order passed under Section 92CA(3) of the Act] Assessment Year 2012-2013 & 2013-2014 18. We note that in the case of the Assessee ... charged in other international transactions of the Assessee (i.e average of 1.5%, 0.66% and 0.70%) which comes to 0.95% [Paragraph 7 of the Transfer Pricing Order passed under Section 92CA(3) of the Act] Assessment Year 2012-2013 & 2013-2014 since the assessee issuing the performance guarantee was not subjected

Dnata International Private Limited, Haryana vs. DCIT, Circle 1(1), Gurgaon Or Assessment Unit, Income Tax Department, Gurgaon

In the result, appeal of the Assessee is allowed

ITA 4532/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldnata International Private Vs Deputy Commissioner Of Limited. Ground Floor, R1, R2, Income Tax, Circle 1(1), Park Centra, Sector-30, Nh-8, Gurgaon Or Assessment Unit, Gurgaon, Haryana Income Tax Department, Pan: Aadcd7460P Gurgaon, Haryana Appellant Respondent Assessee By Sh. Nikhil Tiwari, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

made under Section 92CA of the Act i.e. 30 months (18 months + 12 months) from end of AY 2020-21 Present Case 3 Transfer pricing order under section 92CA(3) of the Act 27 July, 2023 4 Draft Assessment Order 28 September 2022 5 DRP order 24 June

Signify Innovations India Limited, Haryana vs. Deputy Commissioner of Income Tax, Circle 3(1), Haryana

In the result, appeal of the Assessee is allowed

ITA 4510/DEL/2024[2020-2021]Status: DisposedITAT Delhi23 Jan 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsignify Innovations India Limited Vs Deputy Commissioner Of 9B, 9Th Floor, Dlf Cyber City, Income Tax, Circle 3(1), Range Dlf Qe, S.O. Gurgaon, Haryana Code 107, Income Tax Officer, Pan: Aaicp0987G Shankar Chowk, Phase V, Udyogvihar, Sector 19, Gurugram, Haryana Appellant Respondent Assessee By Ms. Reema Grewal, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

sake of ready reference, date Chart filed by the Assessee is reproduced as under: Assessment Year: 2020-21 Relevant Dates : Proceedings 31.07.2023 : Transfer pricing order under section 92CA(3) of the Act passed. 26.09.2023 : Draft assessment order under section 144C(1) of the Act passed 20.06.2024 : DRP directions under section

Airbnb India Private Limited, Delhi, India vs. The Deputy Commissioner of Income Tax, Circle 1(1), Central Revenue Building, Delhi, India

In the result, the appeal of the Assessee is allowed

ITA 4331/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb India Private Limited, Dcit, Circle-1(1), 5Th Floor, Caddie Commercial Central Revenue Building, Tower, Aerocity, Vs. Delhi. New Delhi-110037. Pan-Aakca5525B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 24.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. & 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 27.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 24/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) & Also Airbnb India Pvt. Ltd. Vs. Ito Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

sake of ready reference, date Chart filed by the Assessee is reproduced as under: Assessment Year: 2020-21 Relevant Dates : Proceedings 28.07.2023 : Transfer Pricing order u/s 92CA(3) of the Act passed. 25.09.2023 : Draft assessment order u/s 144C(1)of the Act passed. 30.09.2023 : Limitation for passing the final assessment

Airbnb Payments India Private Limited, Gurugram, Haryana vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana

In the result, the appeal of the Assessee is allowed

ITA 4263/DEL/2024[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb Payments India Private Dcit, Circle-1(1), Limited, Gurugram, Haryana. Level 9, Spaze I Tech Park, Vs A1 Tower, Sector-49, . Sohna Road, Gurugram-122018 Haryana. Pan-Aanca6203B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 18.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 24.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 18/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On Airbnb Payments India Private Limited Vs. Dcit The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 Itr 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

sake of ready reference, date Chart filed by the Assessee is reproduced as under: Assessment Year: 2020-21 Relevant Dates : Proceedings 30.07.2023 : Transfer Pricing order u/s 92CA(3) of the Act passed. 11.09.2023 : Draft assessment order u/s 144C(1)of the Act passed. 30.09.2023 : Limitation for passing the final assessment

Toyota Boshoku Device India Private Limited, Gurgaon, Haryana vs. Assessment Unit, Income Tax Department, Gurgaon, Haryana

ITA 3443/DEL/2024[AAFCT0104J]Status: DisposedITAT Delhi23 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)Section 158A

1 ITA No. 3443/Del/2024 Toyota Boshuoku Device India Pvt. Ltd. vs. A.U IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI

Claas Agricultural Machinery Private Limited, New Delhi vs. Deputy Commissioner of Income-Tax, Circle 4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4563/DEL/2024[AY 2020-21]Status: HeardITAT Delhi21 Jan 2026

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

reproduced as under: 23 ITA No. 4563/Del/2024 Class Agricultural Machinery Pvt. Ltd. Vs. DCIT Assessment Year: 2020-21 Proceedings Relevant Dates : 21.07.2023 : Transfer Pricing order u/s 92CA(3) of the Act passed. 21.09.2023 : Draft assessment order u/s 144C of the Act passed. 24.06.2024 : DRP directions under Section 144C

Itron India Private Limited, Noida vs. The Assistant Commissioner of Income Tax, Circle 10(1), New Delhi

In the result, appeal of the Assessee is allowed

ITA 4389/DEL/2024[2020-21]Status: HeardITAT Delhi21 Jan 2026AY 2020-21

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India Private Limited Vs The Assistant Commissioner C-7, Sector-3, Noida Gautam Of Income Tax, Circle 10(1), Budh Nagar, Uttar Pradesh C. R. Building, I. P. Estate, Pan: Aabcs6575L New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Section 143(3)Section 144BSection 144CSection 153Section 153(1)

Year: 2020-21 Relevant Dates : Proceedings Ground No. 4 : Final Assessment order is time barred by limitation and is bad in law 30.07.2023 : Transfer Pricing order u/s 92CA(3) of the Act. 22.09.2023 : Draft assessment order u/s 144C(1) of the Act passed. 30.09.2023 : Limitation for passing the final assessment

Alcon Laboratories (India) Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle - 1(1)(1), Bangalore

The appeal are allowed with above direction

ITA 1899/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Aseem Sharma, CIT(DR)(ITAT), Bengaluru
Section 143Section 143(1)(a)Section 144CSection 37Section 40

shifting report. He submitted that all these functions are performed for the benefit of associated enterprises and should invariably form part of the transfer pricing order. The report and the illustrative example included therein also recognise that performing these functions and incurring marketing expenditure thereby providing benefit to its associated

Red Hat India Private Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

ITA 3016/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 Jan 2026AY 2011-12
Section 143(3)Section 147Section 148Section 263Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘J’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

making an adjustment to the total income of the Appellant. 2. On the facts and circumstances of the case and in law, the transfer pricing order passed by the learned TPO under section 92CA(3) of the Act further considered by the learned AO and confirmed

DCIT, Bangalore vs. M/S Thomson Reuters India Services Pvt. Ltd., Bangalore

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

average mean of 22.71%. The Ld.TPO thus proposed adjustment being shortfall amounting to Rs. 11,92,96,066/-. 4. On receipt of the transfer pricing order, Ld.AO pass to the draft assessment order on 28/03/2014, by further denying:- • deduction u/s 10A in respect of making disallowance u/s 10A in respect

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

length price by the Transfer Pricing Officer during TP assessment proceedings of LHCC and Kanidi, detailed as under: S. Manufacturing Assessment Refer, Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

length price by the Transfer Pricing Officer during TP assessment proceedings of LHCC and Kanidi, detailed as under: S. Manufacturing Assessment Refer, Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

length price by the Transfer Pricing Officer during TP assessment proceedings of LHCC and Kanidi, detailed as under: S. Manufacturing Assessment Refer, Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

length price by the Transfer Pricing Officer during TP assessment proceedings of LHCC and Kanidi, detailed as under: S. Manufacturing Assessment Refer, Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

length price by the Transfer Pricing Officer during TP assessment proceedings of LHCC and Kanidi, detailed as under: S. Manufacturing Assessment Refer, Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC

Deputy Commissioner of Incometax, Chennai vs. Saint - Gobain India Private Limited, Chennai

In the result, the assessee succeeds

ITA 1672/CHNY/2024[2016-17]Status: DisposedITAT Chennai18 Dec 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 115JSection 143(3)Section 144C(1)Section 153Section 153(1)Section 153(4)Section 92C

ground was filed by the Assessee/ Appellant on 22.10.2025 challenging the AO’s order as time barred on the Jurisdictional ground that the Transfer Pricing Order dated 01.11.2019 and Final assessment order passed u/s 143(3) r.w.s. 144C (3) of the Act dated 28.02.2020 is barred by limitation under section ... Assessee is noted to have filed additional grounds (supra), challenging the AO’s order as time-barred on the Jurisdictional ground that the Transfer Pricing Order dated 01.11.2019 and Final assessment order passed u/s 143(3) r.w.s 144C (3) of the Act dated 28.02.2020 is barred by limitation under section

Saint-Gobain India Private Limited, Chennai vs. DCIT Ncc 8(1), Chennai

In the result, the assessee succeeds

ITA 1505/CHNY/2024[2016-17]Status: DisposedITAT Chennai18 Dec 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Ms.E. Pavuna Sundari, CIT
Section 115JSection 143(3)Section 144C(1)Section 153Section 153(1)Section 153(4)Section 92C

ground was filed by the Assessee/ Appellant on 22.10.2025 challenging the AO’s order as time barred on the Jurisdictional ground that the Transfer Pricing Order dated 01.11.2019 and Final assessment order passed u/s 143(3) r.w.s. 144C (3) of the Act dated 28.02.2020 is barred by limitation under section ... Assessee is noted to have filed additional grounds (supra), challenging the AO’s order as time-barred on the Jurisdictional ground that the Transfer Pricing Order dated 01.11.2019 and Final assessment order passed u/s 143(3) r.w.s 144C (3) of the Act dated 28.02.2020 is barred by limitation under section