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Section 6 of the General Clauses Act, which preserves rights and liabilities under repealed statutes, does not automatically apply to a mere omission of a statutory provision unless the omitting enactment specifically provides for it, thereby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

Dy.Commissioner of Income Tax Circle-3(1)(2), Ahmedabad vs. M/S.Quintiles Research India Pvt.Ltd., Ahmedabad

In the result, the appeal by the assessee is partly allowed and the departmental appeal is dismissed

ITA 946/AHD/2016[2011-12]Status: DisposedITAT Bangalore10 Dec 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2011-12

For Appellant: Shri Ketan Ved, CAFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 153Section 153BSection 92C

time barred. His arguments are as under:- “1. The sole bone of contention left in the instant case is whether the Transfer Pricing Order made by the Transfer Pricing Officer ('TPO') dated 30.01.2015 for Assessment Year 2011-12 ('A.Y 2011-12') was barred by limitation within the meaning of Section

Quintiles Research (India) Pvt. Ltd., Bangalore vs. The Dy.CIT, Circle-3(1)(2), Ahmedabad

ITA 1025/AHD/2016[2011-12]Status: DisposedITAT Bangalore10 Dec 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Ketan Ved, CAFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 153Section 153BSection 92C

time barred. His arguments are as under:- "1. The sole bone of contention left in the instant case is whether the Transfer Pricing Order made by the Transfer Pricing Officer ('TPO') dated 30.01.2015 for Assessment Year 2011-12 ('A.Y 2011-12') was barred by limitation within the meaning of Section

Microsoft Research Lab India Private Limited, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle 4(1)(1), Bengaluru

In the result, the appeal is set aside for doing it denovo

ITA 1842/BANG/2024[AY 2017-18]Status: DisposedITAT Bangalore28 Nov 2025

Bench: Ms. Padmavathy S. & Shri Rahul Chaudhary

For Appellant: Sri Nageshwar RaoFor Respondent: Dr. Divya K.J
Section 143(3)Section 144BSection 144CSection 144C(2)Section 144C(3)Section 153Section 153BSection 250

determined, the Transfer Pricing Oder goes to the assessing officer, the assessing officer shall pass the 143(3) order incorporating the Transfer Pricing Order. The assessing officer has not discussed any thing about the transfer pricing adjustments made by the TPO and has accepted the transfer pricing adjustments in toto

Assisstant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4935/MUM/2024[2017]Status: DisposedITAT Mumbai24 Nov 2025

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

purchased in case of specified domestic transactions at Rs. 3.03/- per unit and made adjustment in the hands of the assessee. 4.3. The transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4933/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Nov 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

purchased in case of specified domestic transactions at Rs. 3.03/- per unit and made adjustment in the hands of the assessee. 4.3. The transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4931/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

purchased in case of specified domestic transactions at Rs. 3.03/- per unit and made adjustment in the hands of the assessee. 4.3. The transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

treated as an adjustment to ALP to the international transaction on account of receipt of management consultancy services.” 5. On receipt of transfer pricing order under section 92 CA (3), the Ld.AO passed draft assessment order on 21/09/2023, by incorporating proposed adjustment by Ld.TPO. 6. On receipt of the draft

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

Mumbai dated 21.05.2015 for A.Y. 2009-10. The assessee in its appeal has raised following grounds of appeal: 1. Adjustment as per Transfer Pricing Order under section 92CA(3) ₹1,84,16,207 [Paras 2 to 16, pages 2 to 8 of the CIT(A) order] ICICI Bank Limited

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

Mumbai dated 21.05.2015 for A.Y. 2009-10. The assessee in its appeal has raised following grounds of appeal: 1. Adjustment as per Transfer Pricing Order under section 92CA(3) ₹1,84,16,207 [Paras 2 to 16, pages 2 to 8 of the CIT(A) order] ICICI Bank Limited

Lm Wind Power As, Denmark vs. Assistant Commissioner of Income Tax, Circle International Tax 2(2)(1), Delhi

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

allowed. 52. With regard to Ground No.7 regarding penalty proceedings under section 271AA of the Act, ld. AR submitted that in the transfer pricing order dated 08.06.2023 passed under section 92CA(3) of the Act, it is alleged that following transactions entered into by the assessee with LM India, have

Sap India Private Limited, Bangalore vs. Jurisdictional Assessing Officer - Deputy Commissioner of Income Tax Circle 6(1)(1), Bangalore

The appeal of the assessee is allowed to the extent indicated above

ITA 1519/BANG/2024[2020-21]Status: DisposedITAT Bangalore17 Nov 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 143Section 144BSection 144C

therefore they should be included. 38. We have carefully considered the rival contention we find that at paragraph No. seven of the transfer pricing order we find that as per the TP study report of the taxpayer it selected eight comparable companies in respect of distribution of software services. These ... learned transfer pricing officer stating that these were not part of the transfer pricing officer search metrics. In paragraph No. 11.2 of the transfer pricing orders the learned TPO has stated that assessee has proposed a new comparables however same were rejected as those they do not appear

Precision Camshafts Limited, Pune vs. DCIT Circle 1, Solapur

In the result, appeal of the assessee is partly allowed

ITA 2744/PUN/2024[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 143(3)Section 144BSection 144C(1)Section 144C(5)Section 153Section 92B

that no guarantee commission needs to be charged. Accordingly, we direct the AO/TPO to delete the addition. ITA No.2744/PUN/2024 [A] 4.6 In the Transfer Pricing Order the TPO has relied on the decision of Hon’ble Bombay High Court in the case of CIT Vs. Everest Kanto Cylinders

M/S. Ambattur Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

ITA 2601/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Respondent: Shri. R. Vijayaraghavan, Advocate
Section 50CSection 56(2)(vii)

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Erevmax Technologies Pvt. Ltd., Kolkata vs. D.C.I.T./A.C.I.T., Tp-1, Kolkata

Appeal of the assessee is partly allowed for statistical purposes

ITA 2551/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: Us In The Paper Book)

Section 143(3)

verify the Profit Split. As a result, the adoption of TNMM Method, the comparison of the Profitability rate with eleven external comparable companies Transfer Pricing Order, and the consequent determination of ALP amount of Rs.17678365/- being 16.85% of the Turnover of the Appellant of Rs. 105274894/-, had been proper

Assistant Commissioner of Income Tax, Jhandewalan Extension, New Delhi vs. Tvarur and Fats Private Limited, New Delhi

In the result, Appeal of the Revenue in ITA No

ITA 3006/DEL/2024[2016-17]Status: DisposedITAT Delhi24 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Assistant Commissioner Vs. Tvarur & Fats Pvt. Ltd. Of Income Tax, Unit No. 101, 102A, First Floor, Room No. 332, 3Rd Floor, Plot No. 9, Realtech Copia, Ara Centre, Jhandewalan Corporate Suits, Jasola District Extension, New Delhi Centre, New Delhi Pan: Aaect7561Q Appellant Respondent C.O. No. 83/Del/2024 (In Ita No. 3006/Del/2024) Tvarur & Fats Pvt. Ltd. Vs. Assistant Commissioner Of Unit No. 101, 102A, First Income Tax, Floor, Plot No. 9, Room No. 332, 3Rd Floor, Ara Realtechcopia, Corporate Centre, Jhandewalan Suits, Jasola District Extension, New Delhi Centre, New Delhi Pan: Aaect7561Q Appellant Respondent Assessee By Sh. Ashwani Kumar, Ca & Sh. Aditya Kumar, Ca Revenue By Sh. S. K. Jadhav, Cit(Dr) Date Of Hearing 05/08/2025 Date Of Pronouncement 24/10/2025

Section 92C

observations and references of the TPO made in 11 ITA No. 3006/Del/2024& C.O. No. 83/Del/2024 ACIT Vs. Tvarur Fats Pvt. Ltd. the Transfer Pricing Order dated 25.10.2019 were irrelevant to the facts of the case. The appellant pointed out that the TPO has misconceived the facts of the appellant

Thyssenkrupp Industrial Solutions Ag, Mumbai vs. Deputy Commissioner of Income Tax Transfer Pricing Circle -4(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3621/MUM/2024[2016-17]Status: DisposedITAT Mumbai15 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarthyssenkrupp Industrial V/S. Deputy Commissioner Of Solutions Ag बनाम Income Tax,Transfer Pricing C/O Mohinder Puri & Co., 1A- Circle – 4(2)(2), Air India D, Vandhna Building, 11 Building, Nariman Point, Tolstoy Marg, New Delhi – Mumbai–400021, Maharashtra 110 001 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcp5301B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nishant Thakkar & Ms. J.Amalsadwala,ARsFor Respondent: Shri Pravin Salunkhe, (Sr. DR)
Section 271GSection 273BSection 92DSection 92D(1)Section 92D(3)

issued calling for detailed information and documents under Section 92D (3) of the Act read with Rule 10D. The TPO thereafter passed Transfer Pricing order determining a transfer pricing adjustment of Rs. 49,86,862/-.Thereafter, penalty notice u/s 271G was issued andpenalty imposing penalty ... Order, that the alleged delay in complying with the 92D(3) notice had in any way impacted his ability to pass the Transfer Pricing Order. Besides, there is no allegation by the TPO that the alleged non-compliance by the assessee was mala fide or with the intention to delay

DCIT, Pune vs. Barclays Global Service Centre Pvt Ltd, Chennai

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

ITA 2353/PUN/2024[2009-10]Status: DisposedITAT Chennai26 Sept 2025AY 2009-10

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./ Ita No.2353/Pun/2024 िनधा8रण वष8 /Assessment Year: 2009-10

For Appellant: Shri Percy Pardiwala, Sr. counselFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 195(2)Section 40

evident that the assessee has paid communication and connectivity charges, which is in the form of reimbursement. The TPO also in the transfer pricing order has not made any adjustment on such reimbursement, as the payment is on the cost-to-cost basis. We do not find any infirmity

Manpowergroup Services India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle 2, Delhi, Jhandewalan Extension, New Delhi

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

ITA 3585/DEL/2024[2020-2021]Status: DisposedITAT Delhi25 Sept 2025AY 2020-2021

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri S.K. Agarwal, ARFor Respondent: Shri Dharm Veer Singh, CIT-DR
Section 143(3)Section 80JSection 92CSection 92D

Total 36,28,32,847 Dedn restricted to gross 24,16,27,837 total income 7. The TPO vide transfer pricing order dated 29 July 2023 and the AO vide draft/final assessment order dated 30 September 2023, made certain additions/denied claims made by the Assessee and assessed the total income

Bmw India Pvt Ltd, Haryana vs. ACIT Circle1(1), Gurgaon

In the result, Appeal of the Assessee is allowed

ITA 2024/DEL/2022[2011-12]Status: DisposedITAT Delhi12 Sept 2025AY 2011-12

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Bmw India Pvt. Ltd. Vs Assistant Commissioner 2Nd Floor, Oberoi Centre Of Income Tax, Circle (1), Building No. 11, Dlf Cyber Hsiidc Building, Vanijya City Dlf Phase, Gurgaon, Nikunj Udhyog Vihar, Haryuana, 122001 Phase-5, Gurgaon, Pan: Aabcb7140C Haryana Appellant Respondent Assessee By Sh. Himanshu S. Sinha-Adv, Ms. Kanika Jain, Adv& Sh. Prashant Meharchandani, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 12/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Challenging The Final Assessment Order Passed By Assistant Commissioner Of Income Tax, Circle -1(1)-Gurgaon, Dated 28/06/2022 U/S254R.W. Section 143(3)/144C Of The Income Tax Act, 1961 ('Act' For Short).

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 254Section 254rSection 92C

facts and circumstances of the case and in law, the Ld. TPO and Ld. AO have erred in passing the transfer pricing order under section 92CA(3) and draft assessment order under Section 144C in pursuance of the Hon'ble Tribunal's order under Section 254 beyond

Netradyne Technology India Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(1)(1), Bengaluru

In the result, the appeal filed by the assessee is partly allowed

ITA 2258/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Sept 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

For Appellant: Shri Suresh Muthukrishnan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144Section 92C

assessment order passed u/s 144 C (1) of the Act dated 10.11.2023 made by the ld. Transfer pricing officer [ the ld. TPO] per Transfer pricing order u/s. 92CA(3) of the Act proposing the above adjustment and pursuant to the direction of the ld. Dispute Resolution Panel-II, Bangalore