“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Section 143(1)Section 143(3)Section 263Section 40A(2)

{ "clean_text": "ITA No. 3533/Del/2025\n\nIN THE INCOME TAX APPELLATE TRIBUNAL\nDELHI BENCH ‘E’: NEW DELHI\nBEFORE SHRI S

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

scrutiny and a reference under section 92CA of the Act was made to the TPO for determination of ALP in respect of international transactions and specified domestic transactions. Several transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated

DCIT, NEW DELHI vs. M/S. ARKADIN CONFER INDIA PVT. LTD., NOIDA

In the result, the appeal of the Revenue in ITA No:- 6037/Del/2015

ITA 6037/DEL/2015[2011-12]Status: DisposedITAT Delhi18 Mar 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Section 143(3)Section 254(2)

India) Pvt. Ltd. in Civil Appeal No.6144 of 2009, order dated 30.08.2018. The ratio of the hon’ble Supreme Court was that where the international transaction was above Rs.5 crores, same should have been referred to Id. TPO for determination of arm's length price of the international transaction ... have carefully perused the material available on record. The issue for adjudication is ascertaining of the Arm’s Length Price of international transactions. In the instant case, we find that the arm’s length adjustment in respect of the international transaction was not referred to the TPO even though

NIDEC MOBILITY INDIA PRIVATE LIMITED,GURGAON, INDIA vs. COMMISSIONER OF INCOME-TAX (APPEAL), CENTRAL NER, GUWAHATI, GUWAHATI

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

ITA 3616/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Mar 2026AY 2018-19

Bench: SHRI RAMIT KOCHAR (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

For Appellant: Sh. Sourav Aggarwal, CAFor Respondent: Sh. S.K. Jadhav, CIT-DR

Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 92C

body control module and key less entry system for cars manufactured in India. The AO observed that the assessee has entered into an international transactions with its AE . A reference was made by the AO u/s 92CA(1) of the Act to the TPO on 27.02.2021 through technical unit

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)

notice u/s 142(1) of the Act. In 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 ... international transaction. The Ld. TPO after considering various 4 Getinge Medical India Private Limited submissions of the assessee in respect of the international transaction proposed an adjustment of Rs.6,85,66,040/- in respect of the AMP expenditure. Thereafter, the Ld. AO while passing the draft assessment order further made

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)

selected for scrutiny and the statutory notices were 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 ... determine the ALP of the said international transaction. The TPO made an adjustment of Rs.7,04,46,005/-. The assessee filed its objections before the DRP against the draft assessment order passed by the A.O incorporating the TP adjustment. Based on the directions of the DRP, the TPO passed

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

nprivate limited company, is engaged in providing SWD services and\nMarketing and Sales Support Activities (MSS) to its AEs. The assessee\nbenchmarked its international transactions under SWD Segment & MSS\nSegment by adopting TNMM as the most appropriate method. The\nassessee worked out the PLI as OP/TC for both segments, which

TEHMINA K KATRAK CHARITABLE TRUST ,MUMBAI vs. ITO WARD 2(4), MUMBAI

ITA 549/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22

Section 11Section 119Section 139Section 154Section 92E

hereby extended to 15th\nFebruary, 2022;\n3. The due date of furnishing of Report from an Accountant by persons\nentering into international transaction or specified domestic transaction\nunder Section 92E of the Act for the Previous Year 2020-21, which was\n31st October 2021, as extended to 30th November

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

Rs.570,05,14,430/- under the normal provisions of the Act and book profit of Rs.1261,54,80,329/- u/s. 115JB. Assessee had undertaken international transactions with its Associate Enterprises (AEs). Case of the assessee was thus, referred to ld. Transfer Pricing Officer (TPO) for computation of Arm’s Length ... Price (ALP) in respect of international transactions. Ld. TPO vide his order u/s.92CA(3) proposed upward adjustment of Rs.45,95,35,746/-, details of which is tabulated below: Glenmark Pharmaceuticals Ltd. AYs 2015-16 and 2016-17 Sr. No. Nature of Transaction Adjustment (Rs.) 1. Export to Glenmark Nigeria

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

TAEGUTEC INDIA PRIVATE LIMITED ,BANGALORE vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result Appeal filed by the Assessee is allowed directing the Assessing

ITA 2265/BANG/2025[2021-22]Status: DisposedITAT Bangalore11 Mar 2026AY 2021-22

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2021-22

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Date of Hearing

Section 143Section 143(1)Section 143(2)Section 143(3)

return of income was picked up for scrutiny by issuing a notice u/s. 143(2) of the Act. The Assessee also entered certain international transactions, and the reference was made to the Ld. Transfer Pricing Officer. No adjustment was proposed. 5. However, the Ld. Assessing Officer noted that

JUBILANT INGREVIA LIMITED,BHARTIAGRAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, MORADABAD

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

ITA 5851/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanjubilant Ingrevia Ltd, Vs. Acit-1, Bhartiagram Bhartia Gram, So Moradabad, Up Dhanaura, Jyotiba Phule Nagar, Uttar Pradesh (Appellant) (Respondent) Pan: Aaecj6722D

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Jitendra Singh, CIT DR

Section 115Section 143(1)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 154Section 234ASection 234CSection 270A

referred to Learned Transfer Basing Officer (TPO) under section 92CA(1) of the Act to determine the arm's length price of the international transactions undertaken by the assessee. The Learned TPO passed an order under section 92CA(3) of the Act dated 30-10-2023 suggesting the transfer basing

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)

Transfer Pricing Officer ('ld. TPO)/ Assessing Officer ('AO') made a TP adjustment to the arm's length price ('ALP') of the assessee's international transaction. While making the TP adjustment, the ld. TPO/AO erred in: 1.1. rejecting the economic analysis undertaken by the assessee in the transfer pricing study report ... 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 duly in Form No.3CEB filed along with the return of income. In order to determine the Arm’s Length Price

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 ... upward adjustment for the arm's length price (ALP) of the international transaction entered into by the assessee, detail of which is tabulated below: Nature of transaction Adjustment Amount (Rs.) Guarantee commission charged by assessee @ 93,33,826 0.31% (INR 300Cr/1.11Cr) (A) Guarantee commission

SURESH KUMAR PODDAR,KOLKATA vs. I.T.O., WARD - 63(4), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 1542/KOL/2024[2011-2012]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 111ASection 132Section 132(1)Section 139(1)Section 144Section 147Section 148Section 153CSection 250Section 250o

cessive loss, deduction, allowance or relief in the return; (ba) where the assessee has failed to furnish a report in respect of any international transaction which he was so required under section 92E] (c) where an assessment has been made, but- (i) income chargeable to tax has been underassessed

M/S. AVM PRODUCTIONS,CHENNAI vs. ACIT, NON CORPORATE CIRCLE-20(1), CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 2359/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

Section 270Section 270A

account; (e) failure to record any receipt in books of account having a bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. M/s. AVM Productions

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. LOYAL TEXTILE MILLS LTD, KOVILPATTI

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

ITA 2308/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Mar 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. Bhupendran, Advocate (Virtual)

Section 143(3)Section 40Section 801ASection 80ISection 92CSection 92F

above decision and held that the transfer pricing provisions do not override the computation mechanism of section 80IA(8) in the absence of any international transaction. The relevant extract of the said decision is as under: “6. We have considered the rival submissions and perused the material available on record ... above decision and held that the transfer pricing provisions do not override the computation mechanism of section 80IA(8) in the absence of any international transaction. Case relied upon by the revenue is not binding on Chennai Bench. The CIT(A) has rightly followed the binding precedent

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

obtaining technical know-how, training and skills relating to extrusion, assembly and marketing of drip irrigation systems. The said transaction was reported as an international transaction under section 92B of the Act and the assessee conducted a transfer pricing study under section 92C of the Act using the Comparable Uncontrolled ... 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 5 DCIT vs. Netafim Irrigation India Pvt. Ltd. manufacturing operations and was accordingly aggregated with other international transactions for the purpose of benchmarking under the TNMM. The aggregation approach adopted by the appellant has not only been consistently followed in earlier years

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

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

also referred reliance of AO on the decision in Perot Systems TSI (India) Ltd. v. DCIT [37 SOT 358 (Del)], which emphasized that all international transactions with AEs must be benchmarked at Arm's Length Price (ALP), regardless of the commercial expediency claimed by the assessee. 7. The Authorised Representative ... period of 180 days, resulting in an upward adjustment of Rs.14,64,47,827/-. It is not disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM, and that working capital adjustment had been undertaken while computing the Profit Level Indicator

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