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“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

The decision most relied on for international transaction is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT (374 ITR 118), cited in 499 judgments on BharatTax.

Leading authorities on international transaction

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India
341 ITR 1 · 2012 · Supreme Court
295
citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

Maruti Suzuki India Ltd. v. CIT
381 ITR 117 · 2016 · High Court
220
citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Vodafone India Services (P.) Ltd. v. Union of India
368 ITR 1 · 2014 · High Court
172
citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

Sir Kikabhai Premchand v. CIT
24 ITR 506 · 1953 · Supreme Court
156
citing judgments

One cannot make a taxable profit or loss from transactions with oneself, as profit only arises from dealings with external third parties, even when transferring assets between different accounts or divisions of the same entity.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT
381 ITR 227 · 2016 · High Court
127
citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

Judgments citing international transaction

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

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

ITA 1763/DEL/2022[2017-18]Status: DisposedITAT Delhi14 Jul 2023AY 2017-18
For Appellant: Shri Himanshu S. Sinha, AdvocateFor Respondent: Shri Jitender Kumar, CIT DR
Section 43BSection 92C

Transfer Pricing Officer ("TPO") erred in making a transfer pricing adjustment of Rs.8,92,28,190/- in respect of international transactions entered by the Appellant alleging the same to be not at arm's length in terms of the provisions of Section 92C of the Act read with Rule

Sona Blw Precision Forgings Ltd., New Delhi vs. Addl. CIT, Special Range-8, New Delhi

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

ITA 525/DEL/2019[2013-14]Status: DisposedITAT Delhi14 Jul 2023AY 2013-14

Bench: Shri Kul Bharat & Dr. B.R.R. Kumar

For Appellant: Ms. Aditi Gupta, ARFor Respondent: Shri Rajesh Kumar, CIT (DR)
Section 143(3)Section 92C

Bevel Gears and Synchronizer rings used in the automobile industry. It was noticed that during the year under consideration, the assessee-company had undertaken international transactions therefore, the matter was referred to Transfer Pricing Officer (TPO) for determining Arms’ Length Price who proposed that adjustment ... value of international transactions against this assessee did not file any objection before the Dispute Resolution Panel (DRP). Thereafter, the Assessing Officer made addition of INR 1,06,66,002/-. Thus, the Assessing Officer assessed the income at INR 29,77,50,298/- against the declared income

Alliance One Industries India Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax Circle 1(1), Guntur

In the result, appeal of the assessee is partly allowed

ITA 68/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam14 Jul 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri K.C. Devdas, ARFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 143(1)Section 143(2)Section 143(3)Section 92C

notice U/s. 143(2) & 142(1) were issued and served on the assessee. The Ld. AO observed that the assessaee has entered into large international transactions with Associated Enterprises [AEs] and thereafter made a reference to the Ld. Transfer Pricing Officer [TPO] for determining the Arm’s Length Price ... dated 29/01/2021. While passing the order U/s. 92CA(3) of the Act, the Ld. TPO observed that as per 3CEB report, the following international transactions entered into by the assessee with its AEs: Sl Associated Nature of Total amount Method No Enterprises International paid / received Transaction or payable / receivable

Lewek Altair Shipping Private Limited, Kakinada vs. DCIT, Circle-1, Kakinada

In the result, appeal filed by the assessee is allowed

ITA 41/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam14 Jul 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri Jitendra Singh, ARFor Respondent: Sri ON Hari Prasada Rao
Section 115VSection 139(5)Section 143(2)Section 143(3)Section 144CSection 92CSection 92E

period of 10 years. The Ld. AO on perusing the income tax return filed by the assessee found that the assessee has entered into international transaction with its Associated Enterprises [AEs] and referred the matter to the Ld. Transfer Pricing Officer [TPO] for valuation of Arm’s Length Price ... 92CA(3) of the Act on 24/12/2020 by making an adjustment of Rs. 2,08,21,534/- as Transfer Pricing adjustment on the international transactions entered into between the assessee and its AEs. The Ld. AO subsequently passed draft order U/s. 143(3) r.w.s 144C

Accenture Solutions P Ltd (Asol), Mumbai vs. Addl/Jt/ Dy/CIT/Asstt/ITO, National Faceless Assessment Centre, Delhi & the Dy CIT, Circle-14(1)(1), Mumbai

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

ITA 1255/MUM/2021[2016-17]Status: DisposedITAT Mumbai13 Jul 2023AY 2016-17

Bench: Shri Amit Shukla & Shri Amarjit Singhaccenture Solutions Vs. Additional/Joint/Deputy/ Private Limited (‘Asol’) Assistant Commissioner Plant 3, Godrej & Boyce Of Income Tax/Income- Complex, Phirojshah Tax Officer, National Nagar, Vikhroli West, Facelless Assessment Off L.B.S Marg, Centre, Delhi Mumbai – 400079 The Dcit, Circle 14(1)(1) स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3235M Appellant .. Respondent Appellant By : Nishant Thakkar/ Hiten Chande/ Ms. Jasmin Amalsadvala Respondent By : Azhar Zain Vayal Parambath Date Of Hearing 22.05.2023 Date Of Pronouncement 13.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ao (National Assessment Centre) Mumbai- 2, Dated 18.03.2021 For A.Y. 2016-17 As Per The Direction Of The Drp Issued U/S 144C (5) Of The Act. The Assessee Has Raised The Following Grounds Before Us: “On The Facts & Circumstances Of The Case & In Law, The Learned Ao Transfer Pricing Officer (Tpo), Based On The Directions Of The Hon'Ble Drp Has: General Ground 1. Erred In Assessing The Total Income Of The Appellant At Rs.2888,33,73,016 Against A Total Income Of Rs.2179,39,30,620 As Reported By The Appellant In Its Revised Return Of Income & Determining A Demand Of Rs.2186,98,55,847 Payable By The Appellant.

For Appellant: Nishant Thakkar/ Hiten Chande/For Respondent: Azhar Zain Vayal Parambath
Section 144CSection 92CSection 92C(3)

assessment order incorporating an invalid adjustment proposed in the TP order. Separate segmental margins 4. Erred in law and facts, in upholding that the international transactions of the Appellant of rendering IT and BPO services under the Delivery Centre Agreement (DCA) are two distinct transactions (i.e rendering of IT services ... alternate TNMM analysis, even if an adjustment is to be made using the TNMM, the adjustment should be restricted to the proportion of the international transaction (e. royalty) to the total costs of the segment. B. Non-Transfer Pricing grounds Non-grant of deduction of education cess paid on income

Abbott India Ltd, Mumbai vs. Addl CIT RG 7(2), Mumbai

In the result appeal filed by the assessee for both the assessment years are allowed

ITA 2032/MUM/2014[2009-10]Status: DisposedITAT Mumbai12 Jul 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Chaudhary, Jm Ita No. 2032/Mum/2014 (Assessment Year2009-10)

For Appellant: Shri Madhur Agrawal,ARFor Respondent: Shri Byomkesh Pradipta Kumar
Section 143(3)Section 144CSection 144C(13)

pharmaceuticals, filed its return of income declaring total income of ₹48,34,49,690/- on 30th September, 2008. As the assessee has entered into international transaction, it was referred to the learned Transfer Pricing Officer to determine the Arm's Length Price of the same. The learned Transfer Pricing Officer

Abbott India Ltd.(Solvay Pharma India Ltd), Mumbai vs. Addl.C.I.T. RG.7(2), Mumbai

In the result appeal filed by the assessee for both the assessment years are allowed

ITA 7778/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Jul 2023AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Chaudhary, Jm Ita No. 2032/Mum/2014 (Assessment Year2009-10)

For Appellant: Shri Madhur Agrawal,ARFor Respondent: Shri Byomkesh Pradipta Kumar
Section 143(3)Section 144CSection 144C(13)

pharmaceuticals, filed its return of income declaring total income of ₹48,34,49,690/- on 30th September, 2008. As the assessee has entered into international transaction, it was referred to the learned Transfer Pricing Officer to determine the Arm's Length Price of the same. The learned Transfer Pricing Officer

Rockwell Automation Private Ltd., New Delhi vs. ACIT, Circle-19(1), New Delhi

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

ITA 1638/DEL/2022[2017-18]Status: FixedITAT Delhi12 Jul 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadrockwell Automation India Private Acit, Circle 19(1), Limited, Vs. Delhi. 131, Functional Industrial Area, Patparganj, New Delhi.

For Appellant: Shri Ajit Jain, AdvocateFor Respondent: Shri Bhaskar Goswami, CIT(DR)
Section 143(1)Section 144C(10)Section 144C(13)Section 92C

AO/Ld. TPO erred in:- 8.1 disregarding that outstanding receivable from the AEs is not a separate transaction but a consequence of international transactions. 8.2 determining the arm’s length price of the impugned international transaction without applying any method prescribed as per Section 92C of the Act. 8.3 not appreciating ... advantage while meeting their specific business objectives. As per Form No. 3 CEB filed along with the return, the assessee company had entered into international transaction with its associated enterprises / concerns during the year. Accordingly, reference was made to the Transfer Pricing Officer to determine the Arm’s Length Price

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

interest on account of difference in arm’s length price of the alleged Page 2 of 19 ITA Nos.4966 & 5064/Del/2019 Omaxe Limited vs. DCIT “International transaction” of financial assistance extended by way of quasi equity to the associated enterprise by disregarding economic substance o the transaction and treating the same ... both on facts and in law in increasing the LIBOR rate by 400 basis points for calculating arm’s length price of the alleged international transaction which is excessive and unreasonable. ITA No.5064/Del/2019 by Revenue. “1. On the facts and in the circumstances of the case

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

interest on account of difference in arm’s length price of the alleged Page 2 of 19 ITA Nos.4966 & 5064/Del/2019 Omaxe Limited vs. DCIT “International transaction” of financial assistance extended by way of quasi equity to the associated enterprise by disregarding economic substance o the transaction and treating the same ... both on facts and in law in increasing the LIBOR rate by 400 basis points for calculating arm’s length price of the alleged international transaction which is excessive and unreasonable. ITA No.5064/Del/2019 by Revenue. “1. On the facts and in the circumstances of the case

Rajasthan Transmat Private Limited, Jaipur vs. Income Tax Officer, Ward 7(2), Jaipur

In the result, the appeal of the assessee partly allowed

ITA 165/JPR/2023[2012-13]Status: DisposedITAT Jaipur11 Jul 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MEETHA LAL MEENA (Accountant Member)

For Appellant: Mrs. Prabha Rana, AR and Shri Vinod Kumar, AdvocateFor Respondent: Mrs. Runi Pal, Addl. CIT-DR
Section 133(6)Section 142(1)Section 143(2)

shares at a premium by the Petitioner to its non-resident holding company does not give rise to any income from an admitted International Transaction. Thus, no occasion to apply Chapter X of the Act can arise in such a case" Further he relied in the case of Green Infra

Assistant Commissioner of Income Tax (It)-4(2)(2), Mumbai vs. M/S Star Cruise Management Ltd, Mumbai

ITA 1296/MUM/2023[2016-2017]Status: DisposedITAT Mumbai10 Jul 2023AY 2016-2017
For Appellant: Shri Madhur AgarwalFor Respondent: Shri Anil Sant
Section 144Section 144C(3)Section 5(2)(a)Section 9(1)(i)

facts and circumstance of the case and in law, the Ld CIT(A) erred in holding that if the consideration in the international transaction between the assessee and Star Travel (India) Travel Services Put Ltd ("SCITSPL") is at an arm's length price, nothing further out of the revenue ... facts and circumstance of the case and in law, the Ld CIT(A) erred in holding that if the consideration in the international transaction between the assessee and Star Travel (India) Travel Services Pvt Ltd (SCITSPL") is at an arm's length price, nothing further out of the revenue

Assistant Commissioner of Income Tax (It)-4(2)(2), Mumbai vs. M/S Star Cruise Management Ltd., Mumbai

ITA 1295/MUM/2023[2017-2018]Status: DisposedITAT Mumbai10 Jul 2023AY 2017-2018
For Appellant: Shri Madhur AgarwalFor Respondent: Shri Anil Sant
Section 144Section 144C(3)Section 5(2)(a)Section 9(1)(i)

facts and circumstance of the case and in law, the Ld CIT(A) erred in holding that if the consideration in the international transaction between the assessee and Star Travel (India) Travel Services Put Ltd ("SCITSPL") is at an arm's length price, nothing further out of the revenue ... facts and circumstance of the case and in law, the Ld CIT(A) erred in holding that if the consideration in the international transaction between the assessee and Star Travel (India) Travel Services Pvt Ltd (SCITSPL") is at an arm's length price, nothing further out of the revenue

DCIT CC 3(4) Cen RG 3, Mumbai vs. Patel Engineering Ltd, Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 2486/MUM/2017[2007-08]Status: DisposedITAT Mumbai07 Jul 2023AY 2007-08

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

thereafter goes on to hold that “the TPO in the facts of the case has not disputed the ALP of this international transaction i.e. he has not disputed the valuation of the shares done by the appellant and submitted to the Transfer Pricing Officer" 4.4 In view of the aforesaid

DCIT CC 3(4) Cen RG 3, Mumbai vs. Patel Engineering Ltd, Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 2485/MUM/2017[2006-07]Status: DisposedITAT Mumbai07 Jul 2023AY 2006-07

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

thereafter goes on to hold that “the TPO in the facts of the case has not disputed the ALP of this international transaction i.e. he has not disputed the valuation of the shares done by the appellant and submitted to the Transfer Pricing Officer" 4.4 In view of the aforesaid

Dhansukhlal Maganlal Dhangar, Na vs. Arivs.Income Tax Officer, Ward - 2, Navsari

In the result, the grounds of appeal raised by the assessee are allowed

ITA 247/SRT/2023[2018-19]Status: DisposedITAT Surat06 Jul 2023AY 2018-19

Bench: Shri Pawan Singh(Physical Hearing) Dhansukhlal Maganlal Dhangar, I.T.O., Shantinagar Society, Ranifaliya, Ward-2, Vs. Vansda, Navsari-396580 (Gujarat) Navsari. Pan No. Acypd 0673 N Appellant/ Assessee Respondent/ Revenue

Section 10Section 142(1)Section 143(3)Section 254(1)Section 270ASection 274Section 80T

account, failure to record any receipt in books of account having a bearing on total income and failure to report any international transaction of any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter-X apply

Gruner India Pvt. Ltd., New Delhi vs. ACIT, Circle- 10(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 4062/DEL/2019[2012-13]Status: DisposedITAT Delhi03 Jul 2023AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 4062/Del/2019 : Asstt. Year : 2012-13 M/S Gruner India Pvt. Ltd., Vs Acit, 15 Dsidc, Okhla Industrial Area, Circle-10(2), Phase-Ii, Scheme-1, New Delhi New Delhi-110020 (Appellant) (Respondent) Pan No. Aadcg2938H Assessee By : Sh. Pancham Sethi, Ca Revenue By : Sh. Mrinal Kumar Das, Sr. Dr Date Of Hearing: 05.04.2023 Date Of Pronouncement: 03.07.2023 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Dated Xx.02.2019 Passed By The Ao U/S 254/143(3) R.W.S. 144C Of The Income Tax Act, 1961. 2. Following Grounds Have Been Raised By The Assessee:

For Appellant: Sh. Pancham Sethi, CAFor Respondent: Sh. Mrinal Kumar Das, Sr. DR
Section 234BSection 254Section 271(1)(c)Section 92C

addition of Rs.3,34,61,905/- made to the income of the assessee u/s 92CA(3). 1.2 Rejecting aggregation-approach under TNMM for benchmarking international transaction at entity level. 1.3 Confirming to benchmark under CUP Method the transaction of Royalty payment even when this is justified under TNMM. 2 Gruner ... ITAT. DRP Directions 2.2.1. These grounds (3-6) relate to the segregated approach adopted by the TPO, treating royalty and FTS transactions as separate 'International Transaction' for the purposes of benchmarking the arm's length price. It is also alleged that the TPO failed to follow the directions

M/S. Brightstar Infrastructure Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/CIT/ITO/NFAC, Delhi

In the result, the appeal of the assesse is allowed

ITA 746/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Jun 2023AY 2017-18
For Appellant: Ketan Ved/Ms. Urvi Mehta/For Respondent: Aditya M Rai
Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 156Section 234BSection 270A

account of an adjustment to Arms Length Price (ALP) of the P a g e | 2 Brightstar Infrastructure Pvt. Ltd. Vs.Add/Joint/DCIT/ITO, NFAC international transaction pertaining to payment of interest on FCCDs by the Appellant to its associated enterprise ("AE"), 3. The Ld AO/1PO/Hon'ble DRP erred rejecting benchmarking approach ... rating, etc.; 5. The Ld AO/Hon'ble DRP erred in rejecting the additional analysis submitted by the Appellant based on comparability factors for benchmarking international transaction relating to payment of interest on FCCDs; 6. The Ld AO erred in not mentioning date of receiving directions from

Lubrizol India Private Limited, Mumbai vs. NFAC, Delhi

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 586/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Jun 2023AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.1464/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2015-16) Lubrizol India Pvt. Ltd. Acit, Circle-3(4) बिधम/ Plant 9/3, Thane-Belapur Aayakar Bhavan, Vs. Road, Turbhe, Navi Maharishi Karve Road, Mumbai-400705. Mumbai-400020. आयकर अपील सं/ I.T.A. No.586/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2017-18) Lubrizol India Pvt. Ltd. बिधम/ National Faceless Plant 9/3, Thane-Belapur Assessment Centre, Delhi. Vs. Road, Turbhe, Navi Mumbai-400705. आयकर अपील सं/ I.T.A. No.1576/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2018-19) Lubrizol India Pvt. Ltd. Dcit/Acit, Circle-3(4) बिधम/ Plant 9/3, Thane-Belapur Mumbai. Vs. Road, Turbhe, Navi Mumbai-400705. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacl0126H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Niraj Sheth/Ms. Urvi Mehta/Abdulkadir Jawadwala Revenue By: Shri Aditya M Rai (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 22/06/2023 घोषणा की तारीख /Date Of Pronouncement: 30/06/2023

For Appellant: Shri Niraj Sheth/Ms. UrviFor Respondent: Shri Aditya M Rai (Sr. AR)
Section 143(3)Section 92C(1)

Lubrizol India Pvt. Ltd. Method (TNMM) as the Most Appropriate Method (MAM) as adopted by the assessee for benchmarking the International Transaction in respect of its Export of Chemical Additives to its Associated Enterprises (AEs) and instead adopting the CUP as the MAM (by relying on the direction ... AO/TPO erred in proposing and the Hon’ble DRP further erred in upholding an adjustment of Rs.25,23,659/- in respect of the International transactions pertaining to export of chemical additives, alleging that the same to be not at arm’s length in terms of the provisions of section

Parle Biscuits Private Limited, Mumbai vs. NFAC, DCIT-2(3)(1), Mumbai

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

ITA 2484/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2023AY 2018-19

Bench: Shri Kuldip Singh () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 270ASection 28Section 40

biscuits, 2 ITA 2484/Mum/2023 Parle Biscuits Pvt Ltd confectionary, snacks and bakery products. During the year under consideration, the assessee has entered into various international transactions as listed below:- Sr.No. Type of Transactions Name of the Associates Amount Enterprises 1 Rendering of technical services Antactic Biscuits ... assessee filed the return of income for A.Y. 20/08/2019 on 29/03/2019, admitting an income of Rs.519,58,54,430/-. Since the assessee had international transaction as listed above, a reference was made to the TPO to compute the arm's length price in relation to the said international transaction