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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

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

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

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
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

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

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

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
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

Cosmo Films Ltd., New Delhi vs. DCIT, Circle- 6(2), New Delhi

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

ITA 7849/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Roycosmo Films Limited, Vs. Dcit, Circle 6 (2), 1008, Dlf Tower A, New Delhi. Jasola District Centre, New Delhi – 110 025. (Pan : Aaacc1152C) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Somil Aggarwal, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 18.09.2025 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 27.10.2013 Passed By The Dcit, Circle 6 (2), Delhi Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2013-14 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144CSection 144C(5)Section 92

That the Ld. AO/ DRP erred on facts and in law in not appreciating that notional interest on receivables does not constitute an international transaction so as to invoke provisions of section 92 of the Income-tax Act, 1961 (lithe Act"). 2.4 That the Ld. AO/DRP erred on facts ... Thermal Lamination machines. 3.2 Further he submitted that as per Form No.3CEB filed along with the return, the assessee company had entered into international transaction with its associated enterprises during the year and accordingly, reference was made to the TPO to determine the Arm's Length Price u/s 92CA

Srf Limited, New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the appeal being ITA No

ITA 4539/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

have grossly erred in holding that extending of corporate guarantee by the assessee to the lending institution of the AEs constitutes an international transaction u/s 92B of the Act. 4. The Ld. DRP/TPO and consequently the Ld. AO have grossly erred in law and on facts and in the circumstances ... pleased to hold:- 6.1 That the act of giving corporate guarantee by the appellant on behalf of the AEs is not an international transaction and, therefore, not amenable to any adjustment under Chapter X of the Income Tax Act. 6.2 In the alternative and without prejudice to the above

Srf Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal being ITA No

ITA 80/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Dec 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

have grossly erred in holding that extending of corporate guarantee by the assessee to the lending institution of the AEs constitutes an international transaction u/s 92B of the Act. 4. The Ld. DRP/TPO and consequently the Ld. AO have grossly erred in law and on facts and in the circumstances ... pleased to hold:- 6.1 That the act of giving corporate guarantee by the appellant on behalf of the AEs is not an international transaction and, therefore, not amenable to any adjustment under Chapter X of the Income Tax Act. 6.2 In the alternative and without prejudice to the above

M/S. Tega Industries Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

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

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

That the Ld. TPO /Ld. AO/ Hon'ble DRP erred in not appreciating the fact that the issuance of corporate guarantee is not an international transaction as per section 92B of the Act without individually appreciating the facts in each case. 2.2. On the facts and circumstances of the case ... Year: 2012-13 I.T.A. No.: 1899/Kol/2017 Assessment Year: 2013-14 is as under: “10. A regards the first contention is concerned, we observe that international transaction has been defined in Section 92B(1) of the Act and the same reads as follows: “92B. (1) For the purposes of this section

Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore vs. Amd India Private Limited, Bangalore

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

ITA 2032/BANG/2024[2013-14]Status: DisposedITAT Bangalore11 Dec 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28

Rs.22,88,94,050. The ITA Nos. 1859 & 2032/Bang/2024 Page 7 of 15 return was picked up for scrutiny. The assessee has entered into international transaction as per Form 3CEB and therefore reference was made to the ld. TPO for determination of the ALP. The assessee has Software Development Services

Vodafone West Limited, (Formerly Known As Vodafone Essar Gujarat Limited), Ahmedabad vs. The Dy.CIT, Circle-4(1)(2), Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 671/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

Ahmedabad has erred in law and on facts in deleting the addition made on account of Arm's Length Price of international transaction as under:" 13a). "The DRP, Ahmedabad has erred in law and on facts in deleting the adjustment made in respect of the determination of ALP for royalty

The Dy CIT, Circle-4(1)(2), Ahmedabad vs. Vodafone West Limited, Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 1634/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

Ahmedabad has erred in law and on facts in deleting the addition made on account of Arm's Length Price of international transaction as under:" 13a). "The DRP, Ahmedabad has erred in law and on facts in deleting the adjustment made in respect of the determination of ALP for royalty

Avl Technical Centre Pvt. Ltd., New Delhi vs. DCIT, Circle-3(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 7705/DEL/2019[2008-09]Status: DisposedITAT Delhi11 Dec 2025AY 2008-09

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhriasstt. Year: 2008-09 Avl Technical Private Limited, Vs Dcit Csc, C-9, Vasant Kunj, Central Circle-3(2) New Delhi-70 New Delhi (Appellant) (Respondent) Pan No. Aadca1470C

For Appellant: Shri Vishal Kalra, Adv. &For Respondent: Shri S.K. Jhadav, CIT( DR)
Section 133(6)Section 143(3)Section 144CSection 14ASection 254Section 92C

Transfer Pricing Officer (TPO") have erred in making the transfer pricing adjustment amounting to INR 1,50,55,862 in respect of international transactions entered by the Appellant with its Associated Enterprises ("AE's"). The CIT(A), further, erred in giving partial relief to the Appellant. (3) That ... circumstances of the case and in law, the CIT(A)VAOTPO have erred in disregarding the benchmarking analysis adopted by the Appellant; wherein the international transactions (except payment of interest on external commercial borrowings) were benchmarked using companies engaged in IT enabled services ("ITes") / Business Process Outsourcing ("BPO") sector

Adp Private Limited, Hyderabad, Telangana vs. DCIT., Circle 1(1), Hyderabad, Telangana

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

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

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 195(2)Section 40

Income Tax Rules, 1962 ('Rules'), and undertaking a fresh economic analysis during the course of assessment proceedings, thereby making an adjustment to the international transaction relating to provision of services and interest on outstanding receivables. 6. Ground 6: Use of additional/modified filters 5 ADP Private Limited ... receivables The Ld. TPO and the Hon'ble DRP erred in: a) Not appreciating that outstanding receivables is not covered in the definition of international transaction as defined u/s 92B of the Act and further erred in making transfer pricing adjustment in the nature of notional interest on receivables amounting

Indeed India Operations Private Limited, Hyderabad vs. ACIT., Circle2(1), Hyderabad

In the result, appeal of the Assessee for the assessment year 2021-2022 is allowed

ITA 943/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad10 Dec 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.943 & 1359/Hyd/2024 Assessment Years 2020-2021 & 2021-2022 Indeed India Operations The Acit, Private Limited, Vs. Circle-2(1), Hyderabad – 500 081. Hyderabad. Telangana Pan Aadci5931J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Mahima Goud, Advocate राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Mahima Goud, AdvocateFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

further erred in upholding confirming the action of the Ld. AO/Ld. TPO in benchmarking outstanding receivables from Associated Enterprises ('AEs) as a separate international transaction, although the receivables are arising out of the principal transactions of rendering software development services which are already benchmarked and tested for arm's length ... each stage of the procedure contemplated. Section 144C envisions a special assessment, one which includes the determination of Arms 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 valuation

Calliduscloud (India) Private Limited, Hyderabad vs. DCIT., Circle- 1(1), Hyderabad

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

ITA 1395/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153

Assessment Unit / learned TPO erred in making an upward adjustment of ₹3,31,04,770/- to the transfer price of the Appellant’s international transactions in respect of SWD services provided by the Appellant to its AEs. 3.2. On the facts and in the circumstances of the case ... 92CA of the Income-tax Act, 1961 was made to the learned Transfer Pricing Officer to determine the arm’s length price of the international transactions undertaken by the assessee. During the TP proceedings, the learned TPO noticed that the assessee had reported various international transactions including provision of software

Indeed India Operations Private Limited, Hyderabad vs. ACIT., Circle -(1), Hyderabad

ITA 1359/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.943 & 1359/Hyd/2024

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

further erred in upholding confirming the action of the Ld. AO/Ld. TPO in benchmarking outstanding receivables from Associated Enterprises ('AEs) as a separate international transaction, although the receivables are arising out of the principal transactions of rendering software development services which are already benchmarked and tested for arm's length

Saxon Global India Private Limited, Hyderabad vs. ITO., Ward-3(1), Hyderabad

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

ITA 1334/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22
Section 144C(5)Section 92C

issued and called for details, and in response, the assessee furnished the return documents, audited financial statements, computation of income, and Form 3CEB reporting international transactions of Rs. 12,74,18,746/- towards provision of services. Considering the substantial international transactions, the A.O. made a reference under Section 92CA ... Global India Private Limited 5. During the Transfer Pricing proceedings, the TPO examined the TP documentation and noted that, the assessee had benchmarked its international transactions by applying TNMM as the most appropriate method with OP/OC as the PLI. The TPO, after considering the functional profile and the filters applied

Parexel International (Irl) Limited, Ireland vs. ADIT (Int Taxn)-2, Hyderabad

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

ITA 447/HYD/2023[2020-21]Status: DisposedITAT Hyderabad10 Dec 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.447/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Parexel International Vs. Additional Director Of (Irl) Limited, Ireland Income Tax Pan:Aaicp4417B Hyderabad (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Advocate Kanchun Kaushal राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Parexel International (Irl) Limited, Ireland (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Adit (Int. Taxation)-2, Hyderabad (“Ld. Ao”) Dated 07.07.2023 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate Kanchun KaushalFor Respondent: : Smt. U Mini Chandran
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 92C

each stage of the procedure contemplated. Section 144C envisions a special assessment, one which includes the determination of Arms 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 valuation

Interwrap Corp Private Limited (Successor of Owens Corning Industries (India) Private Limited), Mumbai vs. DCIT., Circle -5(1), Hyderabad

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

ITA 496/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

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

Section 143(3)Section 144Section 144C(5)

erred in adopting incorrect margin of certain comparable companies. Not restricting the adjustment to the Value of International Transaction. 20. Without prejudice to the above grounds, the Ld. TPO/Ld AO, erred in calculating the Transfer Pricing Adjustment on entity level instead calculating the TP adjustment on the value of international ... transaction. 21. That the Ld. TPO/AO ought to have appreciated that the TP adjustment is more than double the value of actual international transaction which is benchmarked. 5 Interwrap Corp Private Ltd 22. That the Ld. TPO/AO ought to have appreciated that the price/value of the raw materials have

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

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

ITA 491/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 92C

each stage of the procedure contemplated. Section 144C envisions a special assessment, one which includes the determination of Arms 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 valuation

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

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

ITA 490/HYD/2022[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 92C

each stage of the procedure contemplated. Section 144C envisions a special assessment, one which includes the determination of Arms 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 valuation

Ntt Data Business Solutios Private Limited, Hyderabad vs. DCIT, Circle-5(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 489/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.489/Hyd/2022 Assessment Year 2018-2019 Ntt Data Business The Dcit, Solutions Private Limited, Hyderabad. Circle-5(1), Vs. Pin -500081. Hyderabad. Pan Aadci1557Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Aliasgar Rampurawala राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Aliasgar RampurawalaFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 144

Learned Assessing Officer (Ld. AO') /Learned Transfer Pricing Officer ('Ld. TPO') in making an adjustment of INR 27,07,42,005 to the international transaction pertaining to provision of software consultancy and support services and an adjustment of INR 14.43.706 by levying notional interest on trade receivables ... AO/LA. TPO/Hon'ble DRP 5 ITA.No.489/Hyd./2022 erred in computing the adjustment at an entity level instead of restricting to the value of international transactions with the AE and while doing so grossly erred in holding that there is no statutorily audited segmental data available. 15. On the facts