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“associated enterprise”

Transfer PricingSection 92ASection 92A2,562 judgments

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 5560/DEL/2024[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(1)Section 143(1)(a)Section 143(3)Section 80Section 80ISection 92C

contentions referred to page no 653 and 323 of paper book to show that assessee has charged ‘LIBOR’ + 200 bps from its associated enterprises (AE) on foreign currency loans. He reiterated its submission with reliance on ITAT’s ruling in the case of SRF Limited

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 54/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

this case, the Assessing Officer has, inter alia, made addition in respect of specified domestic transactions of purchases made by the assessee from its Associated Enterprises (AE). Accordingly, the issues were referred to the Transfer Pricing Officer for determination of Arm’s Length Price (ALP). The Transfer Pricing Officer suggested ... scrutiny. The Assessing Officer noted from the Form 3CEB furnished by the assessee, the assessee has entered into a purchase transactions with its Associated Enterprises amounting to Rs.37,86,81,489/- out of its total purchases of Rs. 3,73,31,37,156/-. The Assessing Officer by following the order

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 53/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

this case, the Assessing Officer has, inter alia, made addition in respect of specified domestic transactions of purchases made by the assessee from its Associated Enterprises (AE). Accordingly, the issues were referred to the Transfer Pricing Officer for determination of Arm’s Length Price (ALP). The Transfer Pricing Officer suggested ... scrutiny. The Assessing Officer noted from the Form 3CEB furnished by the assessee, the assessee has entered into a purchase transactions with its Associated Enterprises amounting to Rs.37,86,81,489/- out of its total purchases of Rs. 3,73,31,37,156/-. The Assessing Officer by following the order

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), MUMBAI, MUMBAI vs. BLEND FINANCIAL SERVICES LIMITED, MUMBAI

In the result, appeal of the R

ITA 8088/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

For Appellant: Shri Rajesh SanghviFor Respondent: Shri Swapnil Choudhari (SR. DR)
Section 143(3)Section 37Section 40A(2)(b)

renders technology also renders technology-enabled services and knowledge enabled services and knowledge-based backend support to its associated e backend support to its associated enterprise, namely nterprise, namely Blend Management Services FZCO, Dubai, United Arab Emirates, on a Management Services FZCO Dubai, United Arab Emirates, on a cost-plus ... proof of including travel bills, correspondence with clients and proof of including travel bills, correspondence with clients and proof of reimbursement by the associated enterprise in Dubai. T reimbursement by the associated enterprise in Dubai. T reimbursement by the associated enterprise in Dubai. The learned CIT(A) observed that

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

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

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

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

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

response to the statutory notices, assessee furnished various requisite details as called for. As there was international transaction between assessee and associated enterprises that exceeded the threshold limit, reference was made to the Transfer Pricing Officer to determine the arms-length price of the international transaction. The Ld. TPO after

MERIT DATA AND TECHNOLOGY PRIVATE LIMITED,CHENNAI vs. THE INCOME TAX OFFICER, CORPORATE WARD 4(1) CHENNAI, CHENNAI

In the result, the appeal of the assessee is partly allowed and the stay application of the assessee is dismissed as infructuous

ITA 958/CHNY/2026[2022-23]Status: DisposedITAT Chennai12 Mar 2026AY 2022-23

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.958/Chny/2026 & Sa No.74/Chny/2026 (Arises In Ita No.958/Chny/2026) िनधा%रण वष% /Assessment Year: 2022-23 M/S. Merit Data & Technology Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-4(1), Sp 52, 3Rd Street, Ambattur Industrial Chennai. Estate S.O., Ambattur, Tiruvallur – 600 058. Pan: Aadcl 8191M

For Appellant: Mr. K. Prasanna, C.A )*For Respondent: Mr. ARV Sreenivasan, CIT
Section 143(3)

duly served on the assessee. During the year under consideration, the assessee has declared the international transaction towards provision of BPO services to its Associated Enterprises (AE) to the tune of Rs. 92,93,85,577/-. The A.O made a reference to the TPO to determine

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BENGALURU vs. ANALOG DEVICES INDIA PRIVATE LIMITED, BENGALURU

In the result, the Cross Objection is dismissed as infructuous

ITA 2074/BANG/2024[2011-12]Status: DisposedITAT Bangalore12 Mar 2026AY 2011-12
Section 250

nfunctional profile is materially different from that of the assessee, which\nis admittedly engaged only in rendering routine software development\nservices to its associated enterprise.\n\n18.2 We also find merit in the contention that e-Zest Solutions Ltd.\ncarries significant inventory, amounting to nearly 15% of its operating\nincome

DY.COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 143(3)

inclusion of comparable adopted by ld. Transfer Pricing Officer at the time of benchmarking of the transaction undertaken by the assessee with its Associated Enterprises. 4 ITA No. 4907/Mum/2025 and CO No.276/Mum/2025 BP India Pvt. Ltd. AY 2011-12 3. Brief facts of the case are that assessee ... indirect subsidiary of British Petroleum PLC (BP). Assessee primarily provides business support services to various Associated Enterprises (AEs) in the BP group. Return of income for the year was filed on 16.11.2011, reporting total income at Rs.9,46,70,392/-. Assessee had undertaken international transactions with its AEs which were

FIRSTRAND BANK LIMITED - INDIA BRANCH,MUMBAI vs. ASSISTANT COMMISSIONER , MUMBAI

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 133(6)Section 144C(5)Section 92C

which was set off against the brought forward losses of the previous years. 3.1. Assessee had entered into several international transactions with its Associated Enterprise (AE) duly reported in Form 3CEB. Reference was made to ld. TPO against which order u/s.92CA(3) was received by the ld. Assessing Officer, proposing

CA (INDIA) TECHNOLOGIES P.LTD,MUMBAI vs. ITO RG 14(1)(4), MUMBAI

In the result, the appeal is dismissed

ITA 7381/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey, Vp & Shri Makarand Vasant Mahadeokar, Am Ca (India) Technologies Private The Income Tax Officer-14(1)(4) Limited Room No. 458, Aayakar Bhavan, Ground Floor, Vibgyor Tower, Mumbai-400 020 Plot C-62, G-Block, Vs. Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Aaacc 4971 D (Appellant) : (Respondent) Appellant By : None Respondent By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 06.03.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Makarand V. Mahadeokar, Am: This Is An Appeal By The Assessee Against Order Dated 18.09.2018 Of First Appellate Authority, Pertaining To Assessment Year (A.Y.) 2014-15. 2. The Assessee Vide Letter Dated 26.02.2026 Has Submitted That The Dispute Has Been Resolved Through Mutual Agreement Procedure (“Map”) & The Assessee Has Accepted The Map Resolution, Hence, Request Has Been Made For Withdrawal Of The Appeal. The Contents Of The Said Letter Are As Under: Dear Sir, Re: Ca (India) Technologies Private Limited ('Ca India' Or 'Appellant') Permanent Account Number ('Pan'): Aaacc4971D Assessment Year ('Ay'): 2014-15 Appeal No. Ita 7381/Mum/2018

For Appellant: NoneFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C

appeal before your Honours against the final assessment order passed by the Ld. AO 2. During the pendency of above appeal proceedings, the Associated Enterprise (AE') of the Appellant lie. filed by CA Inc ('CA USA') for CA US and its US subsidiaries] had filed MAP application under Article

OWENS CORNING (SINGAPORE) PTE LTD,MUMBAI vs. THE DCIT (INT TAX) CIRCLE-3(2)(2), MUMBAI

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

ITA 5161/MUM/2025[2023-24]Status: DisposedITAT Mumbai26 Feb 2026AY 2023-24

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2023-24 Owens Corning (Singapore) Deputy Commissioner Of Pte Ltd., Income Tax (International Tax), C/O. Owens Corning (India) Vs. Circle-3(2)(2), Pvt. Limited, 6Th Floor, 7Th Floor, Alpha Building, Kautilya Bhavan, Hiranandani Gardens, Bandra Kurla Complex, Powai, Mumbai-400051. Maharashtra-400076. Pan : Aabco5666L (Appellant) (Respondent) For Assessee : Shri Sandeep Bhalla For Revenue : Shri Krishna Kumar, Sr.Dr Date Of Hearing : 02-12-2025 Date Of Pronouncement : 26-02-2026 O R D E R Per Vikram Singh Yadav, A.M : The Assessee Has Filed The Present Appeal Against The Final Assessment Order Dated 10-07-2025, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 („The Act‟), Pursuant To The Directions Issued By The Learned Dispute Resolution Panel-2, Mumbai, ("Ld.Drp"), Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 115ASection 142(1)Section 143(2)Section 143(3)Section 234Section 234BSection 9(1)(vii)Section 90(2)

from the computation of income that the assessee has claimed the receipt of fabrication charges of Rs. 21,96,83,550/- from its Indian associated enterprises, namely, Owens-Corning India Pvt. Ltd. ("OCIPL"), as non- taxable in India as the assessee claims that it has neither any Permanent Establishment ... under Article 12(4)(c) of the India-Singapore DIAA since the assessee does not transfer any technical plan or design to the Indian associated enterprises. Accordingly, the assessee submitted that the receipt for fabrication charges is not taxable at all in India. In support of its submission, the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

under consideration pertains to the determination of the ALP of the royalty payment of Rs.11,00,82,626/- made by the appellant to its associated enterprise, Netafim IS, under a Technical Collaboration Agreement. It is the appellant's contention that the royalty paid at 4% of adjusted sales ... case and in law, the Ld.CIT (A) erred in deleting of Rs.11,00,82,626/- adjustment made on account of Royalty payment to Associated Enterprise (AE) without appreciating that there was no justification by assessee for payment of royalty to AE? (ii) On the facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

under consideration pertains to the determination of the ALP of the royalty payment of Rs.11,00,82,626/- made by the appellant to its associated enterprise, Netafim IS, under a Technical Collaboration Agreement. It is the appellant's contention that the royalty paid at 4% of adjusted sales ... case and in law, the Ld.CIT (A) erred in deleting of Rs.11,00,82,626/- adjustment made on account of Royalty payment to Associated Enterprise (AE) without appreciating that there was no justification by assessee for payment of royalty to AE? (ii) On the facts and circumstances of the case

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

LIBOR with a different mark- up and further addition of 100 basis points towards alleged forex risk adjustment in respect of loans advanced to Associated Enterprises (AEs). The Revenue has also challenged the rejection of the external CUP method adopted by the TPO. 4.1 The Ld. AR submitted that ... wherein the Tribunal, after detailed examination, held as under:- “Ground No. 1(i) - Transfer Pricing Adjustment on Interest on Advances to Associated Enterprises 5. The assessee had during the year under consideration advanced loans to its Associated Enterprises (AEs) in foreign currency aggregating Rs.5,85,87,394/-. These advances were

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

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

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22
For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)
Section 143(3)

comparables on account of material functional differences. It\nwas explained that the assessee is only engaged in providing routine\nsoftware development services to its associated enterprise.\n6.3 In contrast, the impugned comparables were stated to be\nengaged in activities such as development and sale of software products,\nPage ... engaged in development and distribution of\nsoftware products. It was contended that the appellant merely acts as a\ndistributor/reseller of software products of its associated enterprise and\ndoes not undertake any product development, research and\ndevelopment activities, or intellectual-property creation.\n11.2 The Ld. AR further submitted that the lower

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

Officer (for short ‘the TPO’) for determination of Arm’s Length Price (ALP) of the international transactions entered into by the Assessee with its Associated Enterprises (AEs) during the relevant previous year. The TPO passed Order, dated 26/10/2023, under Section 92CA(3) of the Act. The TPO proposed Transfer Pricing

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

adjudication, project administration support, reconciliation\nservices etc. which formed part of the Information Technology\nEnabled Services (ITeS) Segment.\nThe Assessee provided SWD Services to Associated Enterprises\n(AEs) in United States of America [for short `US AEs'] and AEs in\nother countries (for short `Non-US AEs') for which ... which,-\n(i) the net profit margin realised by the enterprise from an\ninternational transaction or a specified domestic transaction\nentered into with an associated enterprise is computed in\nrelation to costs incurred or sales effected or assets\nemployed or to be employed by the enterprise or having\nregard

DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 1560/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

stating the reasons that there was\nno additional financial cost incurred by the assessee to provide the comfort\nletter /undertakings on behalf of its Associated Enterprises (AE). Giving further\nreasoning that the assessee bank was not actually required at any point of time\nduring the concerned year to make good

ICICI BANK LTD,MUMBAI vs. DCIT 2(3)(2), MUMBAI

Appeal is partly allowed

ITA 1446/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

stating the reasons that there was\nno additional financial cost incurred by the assessee to provide the comfort\nletter /undertakings on behalf of its Associated Enterprises (AE). Giving further\nreasoning that the assessee bank was not actually required at any point of time\nduring the concerned year to make good

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 133(6)Section 92D

nstatutory notice, assessee furnished requisite details as called\nfor. The Ld. AO observed that assessee had entered into\ninternational transaction with its associated enterprise for both\nyears that exceeded the threshold limit.\n2.1Accordingly, a reference was made to the Transfer Pricing\nOfficer to determine the arm's-length price ... nstatutory notice, assessee furnished requisite details as called\nfor. The Ld. AO observed that assessee had entered into\ninternational transaction with its associated enterprise for both\nyears that exceeded the threshold limit.\n2.1Accordingly, a reference was made to the Transfer Pricing\nOfficer to determine the arm's-length price

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