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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

Eaton Power Quality Private Limited, Puducherry vs. The Deputy Commissioner of Income Tax, Puducherry

In the result, appeal filed by the assessee is allowed

ITA 231/CHNY/2025[2021-22]Status: DisposedITAT Chennai18 Dec 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Vishal Kalra, AdvocateFor Respondent: Mr. ARV Sreenivasan, CIT
Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 153Section 153(1)Section 92C

income of Rs.42,17,79,822/-. During scrutiny proceedings, the AO noted from perusal of Form 3 CEB that the assessee had entered into international transactions with its AE to the tune of Rs.374,44,64,091/-. Accordingly, a reference was made by AO to the Transfer Pricing Officer ... determine the ALP in respect of the international transactions entered into by the assessee with its AE; and pursuant thereto, the TPO vide order dated 27.10.2023 made adjustment of Rs.29,88,48,209/-. Pursuant thereto, the AO passed the draft assessment order on 20.12.2023 computing total income of the assessee

Ntt Data Global Delivery Services Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax Circle-5(1)(1), Bangalore

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

ITA 2062/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

reproduced herein. 3. The ground Nos. 1 to 9 of the revised grounds of appeal pertain to TP adjustment made in relation to international transaction with the US based AE. 4. At the outset, we note that these grounds have been withdrawn vide order sheet entry dated 15th September ... ground Nos. 10 to 14 of the revised grounds of appeal pertain to TP adjustment made in relation to international transaction with the non-US based AE. 6. At the outset, we note that the assessee, through the learned AR submitted to keep this issue open. Hence

Ntt Data Global Delivery Services Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(1)(1), Bangalore

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

ITA 1720/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

reproduced herein. 3. The ground Nos. 1 to 9 of the revised grounds of appeal pertain to TP adjustment made in relation to international transaction with the US based AE. 4. At the outset, we note that these grounds have been withdrawn vide order sheet entry dated 15th September ... ground Nos. 10 to 14 of the revised grounds of appeal pertain to TP adjustment made in relation to international transaction with the non-US based AE. 6. At the outset, we note that the assessee, through the learned AR submitted to keep this issue open. Hence

Krishna Prabha Sundarapandy, Kanchipuram vs. DCIT, Corporate Circle-6(2), Chennai

In the result, the appeal of the assessee is allowed

ITA 2304/CHNY/2025[2022-23]Status: DisposedITAT Chennai17 Dec 2025AY 2022-23

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2304/Chny/2025 िनधा%रण वष% /Assessment Year: 2022-23

For Appellant: Mr. S. Jayakumar, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 143(3)Section 250Section 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.” 6. The contention

Eli Lilly and Company (India) Private Ltd., Haryana vs. ACIT Circle-1(1), Haryana

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

ITA 973/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Dec 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2018-19] Eli Lilly & Company Assistant Commissioner Of Income (India) Private Limited (‘Eli Tax, Circle-1(1), Haryana, Lilly India”) Vs Additional/Joint/Deputy/Income Plot No.92, Sector-32, Tax Officer/National Faceless Institutional Area, Jharsa, Appeal Centre, Gurgaon, Haryana-122001 New Delhi Pan Aaace8901F Appellant Respondent Assessee By Shri K. M. Gupta, Adv. & Shri Jaskaran Singh, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 17.12.2025

Section 143(3)Section 144Section 144BSection 270ASection 92C(3)Section 92D

read with Rule 10D of the Income-tax Rules, 1962 ('the Rules'), and has further erred in conducting a fresh economic analysis for the international transaction pertaining to provision of business support services and holding that the transaction is not compliant with the arm's length pricing range; 2.3. Excluding

Spectris Technologies Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, the appeal of the assessee is allowed for statistical purpose with above observations

ITA 3563/DEL/2014[2008-09]Status: DisposedITAT Delhi17 Dec 2025AY 2008-09

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2008-09] Spectris Technologies Pvt. Vs. Acit Ltd., 201-B, Second Floor, New Delhi Park Centra, Sector -30 Gurgaon Pan No. Aagcs6654R Appellant Respondent Assessee By Sh. Tarandeep Singh, Advocate Revenue By Ms. Priya Goel, Sr. Dr Date Of Hearing 10.10.2025 Date Of Pronouncement 17.12.2025 Order Per C.N. Prasad, Jm, This Appeal Is Filed By The Assessee Against The Order Of The Ld.Commissioner Of Income Tax (Appeals) -20, New Delhi Vide Order Dated 27.03.2014 For The A.Y. 2008-09. The Assessee Has Raised Following Grounds :- 1. That On The Facts & Circumstances Of The Case & In Law, The Order Passed By The Ld. Commissioner Of Income-Tax (Appeals)-Xx, New Delhi ("Cit(A)") Is Bad In Law.

Section 234BSection 92Section 92C

returned income of the Appellant made by the Ld. AO and Ld. TPO by re-computing the arm's length price of the international transactions under section 92 of the Act. 3.The Ld. CIT(A) erred in facts and in law by upholding the rejection of the transfer pricing methodology ... Resale Price Method adopted by the Appellant in favour of Transaction Net Margin Method (TNMM) as the most appropriate method for benchmarking the international transactions under AMC segment. 3.3 Selecting inappropriate comparable set in application of the transfer pricing methodology adopted by him. 4. The CIT(A) erred in facts

Cinepolis India Pvt. Ltd., Gurgaon vs. ITO Ward - 1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 829/DEL/2021[2016-17]Status: DisposedITAT Delhi16 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Ms. Renu Jauhri[Assessment Year: 2016-17] Cinepolis India Pvt. Ltd., Additional / Joint/ Deputy / 10Th Floor, Dlf Two Horizon Assistant Deputy Centre, Dlf V, Vs Commissioner Of Income Tax, Gold Course Road, Income Tax Officer, Gurugram-122002, National E-Assessment Haryana, India. Centre, Delhi. Pan- Aadcc2076J Assessee Revenue

Section 143(3)Section 271(1)(c)Section 92Section 92C

92CA(3) of the Act of the transactions with its AEs. The TPO proposed adjustment on account of ALP in respect of following international transactions: Sr. No. Nature of transaction Adjustment u/s 92CA(Rs.) 1. Interest on CCDs 9,35,08,334/- 2. Payment of Royalty ... factual background of the instant case has been submitted as under: “1. ……. 2. During AY 2016-17, the Appellant had entered into various international transactions with its Associated Enterprise ("AEs"). In compliance with Section 92D of the Income Tax Act, 1961 ("the Act") read with Rule 100 of the Income

Assistant Commissioner of Income Tax, Circle-1, Dibrugarh vs. Greenply Industries Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 140/GTY/2024[2013-14]Status: DisposedITAT Guwahati15 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

For Appellant: Shri Ashok Tulsyan, ARFor Respondent: Shri Sanjay Jha, DR
Section 115J

Greenlam Asia (referred to pages 478 to 485 of the paper book). Ld. Assessing Officer during the course of assessment proceedings observed that international transaction has taken place and referred the matter to Transfer Pricing Officer, who after considering the submission of the assessee, held that Corporate Guarantee fees ... before the ld. CIT(Appeals) firstly claiming that the said Corporate Guarantee given to the Associated Enterprises do not come under the purview of international transactions and also raising an alternative plea that in view of the settled judicial precedence and looking to the facts of the case, the estimated

Shri Sureshkumar Harjivanbhai Chandarana, Rajkot vs. The ACIT, Circle - 2 (2) (1), Rajkot

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

ITA 415/RJT/2023[2016-17]Status: HeardITAT Rajkot15 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Durga Dutt, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

impact in subsequent years as well. Under the Transfer Pricing Laws in India, there is a rebuttable presumption in law that transfer prices in international transactions or SDTs with the AEs are fixed at variance from Arm's Length Price. The onus is on the assessee to show that

Joshi Technologies International Inc India Projects, Ahmedabad vs. The ACIT (Int. Taxa-1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

facts, in making an upward adjustment of Rs. 35,19,439 to the total income of the Appellant in respect of international transaction of allocation of General and Administrative ("G&A") costs permissible as per Production Sharing Contracts (PSC) by determining the arm's length price (ALP) of the international ... statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

Joshi Technologies International Inc India Projects, Ahmedabad vs. The ACIT (Int. Taxa-1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 80/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

facts, in making an upward adjustment of Rs. 35,19,439 to the total income of the Appellant in respect of international transaction of allocation of General and Administrative ("G&A") costs permissible as per Production Sharing Contracts (PSC) by determining the arm's length price (ALP) of the international ... statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

Joshi Technologies International Inc India Projects, Ahmedabad vs. Assistant Commissioner of Income Tax, Circle(Int.Taxn.)-1, Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 244/AHD/2022[2019-20]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

facts, in making an upward adjustment of Rs. 35,19,439 to the total income of the Appellant in respect of international transaction of allocation of General and Administrative ("G&A") costs permissible as per Production Sharing Contracts (PSC) by determining the arm's length price (ALP) of the international ... statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

Tmeic Industrial Systems India Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 898/HYD/2024[2020-21]Status: DisposedITAT Hyderabad12 Dec 2025AY 2020-21

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.898/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) M/S. Tmeic Industrial Vs. Dy.Cit Systems India Private Limited Circle 2(1) Hyderabad Hyderabad Pan: Aadct5493J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.As, K. C. Devdas, Kranthi Palivela & Mrudulatha राज" व "ारा/Revenue By: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 08/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: C.As, K. C. Devdas, KranthiFor Respondent: Smt. U. Mini Chandran, CIT (DR)
Section 143(3)Section 254

each stage of the procedure contemplated. Section 144C envisions a special assessment, one which includes the determination of Arm’s Length Price (ALP) of international transactions engaged in by the assessee. The DRP was constituted bearing in mind the necessity for an expert body to look into intricate matters concerning

Gainsight Software Private Limited, Hyderabad vs. DCIT., Circle-2(1), Hydersabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 796/HYD/2024[2020-21]Status: DisposedITAT Hyderabad12 Dec 2025AY 2020-21

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92D

upholding the action of the Ld. AO/Learned Transfer Pricing Officer ("Ld. TPO") in making an adjustment of Rs. 6,06,64,773 to the international transaction pertaining to provision of software development and support services. 4. On the facts and in the circumstances of the case ... case and in law, the learned AO/TPO erred in not adopting the upper turnover filter while doing the comparability analysis for the Appellant's international transaction pertaining to provision of Software Development Segment ("SWD") segment. 7. On the facts and in the circumstances of the case

Dsm Shared Services India Private Limited, Hyderabad, Telangana vs. DCIT., Circle 8(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1358/HYD/2024[2021-22]Status: DisposedITAT Hyderabad12 Dec 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1358/Hyd/2024 Assessment Year 2021-2022 Dsm Shared Services India Private Limited, The Dcit, Circle-8(1), Hyderabad – 500 081. Hyderabad – 500 081. Vs. Telangana. Telangana. Pan Aadcd8407C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 09.12.2025 घोषणा की तारीख/Pronouncement: 12.12.2025 आदेश/Order

For Appellant: CA Aliasgar RampurawalaFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144Section 144C(13)Section 153Section 92C(3)

filters which are not relevant to the Appellant. c. not adopting the upper turnover filter while doing the comparability analysis for the Appellant's international transaction under the segment. d. including following companies which are not functionally comparable to the Appellant: I. Infosys BPM Ltd. II. Integra Software Services ... TPO/AO erred in computing the adjustment at an entity level instead of 5 ITA.No.1358/Hyd./2024 restricting to the segment pertaining to the international transaction with the AE Interest on delayed receivables 7. On the facts arid circumstances of the case and in law, the Hon'ble DRP/Ld. AO/Ld

Western Up Tollway Limited, New Delhi vs. DCIT Circle -8(1), Hyderabad

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

ITA 67/HYD/2022[2017-18]Status: DisposedITAT Hyderabad12 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

For Appellant: Advocates Ajay Vohra & AnanyaFor Respondent: : Smt. U. Mini Chandran, CIT (DR)
Section 270ASection 92CSection 92C(3)

connection with the transaction pertaining to "Interest paid on Non-Convertible Debentures ("NCDs")" by the appellant and holding that the international transaction is not at arm’s length. 3. That on facts, the Hon'ble DRP has erred in confirming the action of Ld. AO/ TPO and rejecting the claim ... grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price of the impugned international transaction without applying any method and without performing any analysis in accordance with the provisions of Section 92C of the Act read with Rule

Western Up Tollway Limited, Noida vs. ACIT, Circle-8(1), Hyderabad

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

ITA 493/HYD/2022[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

For Appellant: Advocates Ajay Vohra & AnanyaFor Respondent: : Smt. U. Mini Chandran, CIT (DR)
Section 270ASection 92CSection 92C(3)

connection with the transaction pertaining to "Interest paid on Non-Convertible Debentures ("NCDs")" by the appellant and holding that the international transaction is not at arm’s length. 3. That on facts, the Hon'ble DRP has erred in confirming the action of Ld. AO/ TPO and rejecting the claim ... grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price of the impugned international transaction without applying any method and without performing any analysis in accordance with the provisions of Section 92C of the Act read with Rule

Mahua Bharatpur Expressways Limited, Hyderabad vs. DCIT, Circle-5(1), Hyderabad

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

ITA 170/HYD/2022[2017-18]Status: DisposedITAT Hyderabad12 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

For Appellant: Advocates Ajay Vohra & AnanyaFor Respondent: : Smt. U. Mini Chandran, CIT (DR)
Section 270ASection 92CSection 92C(3)

connection with the transaction pertaining to "Interest paid on Non-Convertible Debentures ("NCDs")" by the appellant and holding that the international transaction is not at arm’s length. 3. That on facts, the Hon'ble DRP has erred in confirming the action of Ld. AO/ TPO and rejecting the claim ... grossly erred in facts and circumstances of the case and in law by: a) Determining of the arm's length price of the impugned international transaction without applying any method and without performing any analysis in accordance with the provisions of Section 92C of the Act read with Rule

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

amounting to Rs. 1,19,57,051/- and grant the refund along with the interest. GROUNDS OF APPEAL - TRANSFER PRICING ADJUSTMENTS INTERNATIONAL TRANSACTIONS – ADJUSTMENTS OF RS.2,50,60,929/- I. Provision of Management Support Services (MSS) – Adjustment of Rs. 34,41,669/- 9.0 That the Ld. DRP and consequently ... facts & circumstances of the assessee’s case in making an adjustment of Rs. 34,41,669/- in respect of international transaction of provision of management support services amounting to Rs. 3,90,89,223/-. 10.0 That the Ld. TPO/Ld. DRP and consequently the Ld. AO have erred

Swatch Group (India) Retail Private Limited, Delhi vs. The Deputy Commissioner of Income Tax, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 4281/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Royswatch Group (India) Retail Private Ltd., Vs. Dcit, Circle 22(2), 4Th Floor, Rectangle 1, Plot No.D4, Delhi. Saket District Centre, Saket, New Delhi – 110 017. (Pan : Aavcs7960H) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 16.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 26.07.2024 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144B 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 :-

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)Section 92D

erred in making an adjustment of INR 1,55,20,501 by disregarding the arm's length analysis undertaken by the Appellant for its international transactions, and in doing so, have grossly erred in: 2.1 Not appreciating that none of the conditions set out in section ... case and in law, the Ld. AO and Ld. TPO erred in not appreciating the business operations of the Appellant with respect to the international transactions viz-a- viz its domestic retail business. TP adjustment with respect to interest computed on outstanding receivables 3. On the facts and circumstances