“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

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

undertaking given by the assessee in the letter of undertaking tantamount to "any service, benefit or facility" to its AE and therefore is an international transaction." 6. On facts and circumstances of the case and in law the Ld CIT(A) erred in holding that "no transfer pricing adjustments ... assessee in issuing the letter of undertaking and thereby overlooking Rule 10B(2)(b) which is an essential factor for comparability of an international transaction. ICICI Bank Limited ITA No. 1550/Mum/2016 (AY 2009-10) 7 On facts and circumstances of the case

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

Lm Wind Power As, Denmark vs. Assistant Commissioner of Income Tax, Circle International Tax 2(2)(1), Delhi

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) 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 :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

That the assessing officer/ TPO erred on facts and in law in initiating penalty proceedings under section 271AA of the Act, without appreciating that international transactions from which no income chargeable to tax arose were not required to be reported by the Assessee in Form No.3CEB.” 2. At the outset ... transactions. 271AA. (1) Without prejudice to the provisions of section 270A or section 271 or section 271BA, if any person in respect of an international transaction or specified domestic transaction,— (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section

Amway India Enterprises Private Limited, New Delhi vs. DCIT, Circle 1(1), Delhi / NFAC, Delhi

Appeal of the assessee is allowed

ITA 5912/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

Section 143(1)(a)Section 143(2)Section 143(3)Section 80GSection 92C

vide its impugned order dated 25.09.2024 has supported the order of the TPO and held that the AMP expenditure claimed by the assessee is international transaction and further observed that the assessee is not a mere distributor of the products of the AE, rather it is providing large number ... transfer pricing regulations. 9. The Ld. TPO/AO/DRP has erred on facts and in law in holding AMP expense incurred by the assessee as an international transaction under section 928 of the Income Tax Act, 1961 without proving existence of any actual understanding/arrangement between the assessee and the associated enterprise

DCIT Circle 1(1), New Delhi vs. Acme Tele Power Ltd. (Now Known As Acme Cleantech Solution Ltd.), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

telecom sites. The return of income was filed declaring loss of INR 78,66,48,709/- on 30.11.2011. As in this case, there were international transactions therefore, a reference was made to the Transfer Pricing Officer (“TPO”) for determination of Arm’s Length ITA No.3641/Del/2017 & Others Price (“ALP”) in respect ... international transactions. The TPO passed the order u/s 92CA of the Act on 12.01.2015 wherein total adjustments of INR 11,62,89,103/- were proposed on the loans advanced to its Associated Enterprises (“AEs”) and further adjustment of INR 33,33,195/- is proposed on the outstanding receivables. Thereafter

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

Penninti Vivekananda Rao, Hyderabad vs. ADIT (Int Taxn)-2, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1494/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Nov 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1494/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Penninti Vivekananda Vs. Adit (International Rao, Hyderabad Taxation)-2 Pan:Ayupp1895L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H Srinivasulu राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Penninti Vivekananda Rao (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.07.2025 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate H SrinivasuluFor Respondent: : Smt. U Mini Chandran, CIT(DR)

Section 143(2)Section 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.” 9. On perusal

Vermeiren India Rehab Private Limited, Tirupati vs. DCIT., Circle-1(1), Tirupati

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

ITA 1315/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Sandeep Bagmar R, AdvocateFor Respondent: MS. U. Mini Chandran, CIT-DR

Section 143(3)Section 144C(5)Section 32

Learned Transfer Pricing Officer ("Ld. TPO) have erred in making the transfer pricing adjustment of INR 1,95,55,466 to the international transactions relating to manufacture and sale of Wheelchairs to Associated Enterprises ("AE"). 1.3. In the facts and circumstances of the case ... facts and circumstances of the case, the Ld. DRP and Ld. TΡΟ/ΑΟ have erred in considering receivables outstanding from AE as an international transaction and have erred in not accepting the contention of the Appellant that it does not fall within the purview of capital financing as stated under

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R

Section 144Section 144CSection 144C(5)Section 92C

various clients as well as providing media planning services to its clients. The Assessee during the assessment year under consideration, had carried out following international transactions with its Associate Enterprises (in short “AEs”): Sr. Nature of Transaction Receipt/ Amount of Method used No. Payment Transaction by Taxpayer (Rs) to determine ... Assessing Officer (AO) consequently, made a reference u/s 92CA(1) of the Act for computation of arm’s length price qua international transactions, as reproduced above. 4. The Transfer Pricing Officer (in short “TPO”) thus initiated the transfer pricing proceedings and vide order dated 16.10.2023 u/s 92CA

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

were issued. In the course of assessment proceedings, it came to the notice of the Assessing Officer that the assessee had entered into substantial international transactions with its associated enterprises. Accordingly, the matter was referred to the Transfer Pricing Officer (TPO), Ward 4(1)(1), under section 92CA for determination ... circumstances between the aforesaid two segments 4.6 Not appreciating provisions of Rule 10B(2) of Income Tax Rules, 1962 ('The Rules') for benchmarking this international transaction, wherein the rule recognizes conditions prevailing in the markets in which the respective parties to the transactions operate, including the geographical location and size

Sap India Private Limited, Bangalore vs. Jurisdictional Assessing Officer - Deputy Commissioner of Income Tax Circle 6(1)(1), Bangalore

The appeal of the assessee is allowed to the extent indicated above

ITA 1519/BANG/2024[2020-21]Status: DisposedITAT Bangalore17 Nov 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 143Section 144BSection 144C

group entities. These services include the implementation of software systems, customisation of software products and business solutions. Assessee has entered into an international transaction of royalty payment in respect of software licensing and maintenance revenue of ₹ 18,779,470,918, cost of purchase services received from its associated enterprises ... services and support services provided by its associated enterprises of ₹ 5,814,382,000 117/–. With the respect to the total international transactions of ₹ 4096 crores, the assessee adopted transactional net margin method as the most appropriate method. The assessee computed the independent margin in its distribution activity and consultancy

Aditya Birla Nuvo Ltd (Since Amalgamated With Grasim Industries Limited), Mumbai vs. DCIT CC-1(4) Earlier With ACIT(Ltu) 1, Mumbai

In the result, theappeals filed by the assessee and revenue are partly

ITA 563/MUM/2018[2013-14]Status: DisposedITAT Mumbai17 Nov 2025AY 2013-14

Bench: The Hon’Bleunder Section 255(4) Of The Act. The Points Of Difference Were Thereafter Referred To The Hon’Blefor Resolution. The Hon’Blehas Now Rendered His Detailed Opinion & The Appeals Have Been Placed Before Us To Pass The Consequential

Section 255(4)Section 80

with a small captive generation plant. Rule 10B(2) prescribes the factors for comparability analysis of either goods or services in relation to an international transaction or SDT with an uncontrolled transaction. The factors which needs to be considered are : (i) the specific characteristics of the property transferred or services

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

Automation India Private Limited vs. DCIT income of the Appellant on account of the difference in the arm's length price (ALP) of its international transactions under the provisions of Section 92CA(4) of the Act. 2. On the facts and in law, the Hon'ble DRP has grossly erred ... computing the net profit margin of Siemens Ltd. 8. On the facts and in law, the Revenue erred in disregarding the fact that subject international transaction was accepted by the Ld. TPO in all preceding assessment years and the facts and circumstances, including even Functions, Assets and Risk ('FAR') profile

M/S R D Construction, Bhilai vs. ITO, Ward-1(5), Bhilai

In the result, appeal of the assessee is allowed

ITA 640/RPR/2025[2017-18]Status: DisposedITAT Raipur14 Nov 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.640/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 M/S. R D Construction Shikshit Nagar, Near Bus Stand, Bhilai Marshalling Yard, Charoda, Bhilai-490 025 (C.G.) Pan: Aajfr3698E

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 115JSection 143Section 143(3)Section 270ASection 270A(1)

length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB ... 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

Sempertrans India Private Limited, Roha vs. Income-Tax Officer, Panvel

In the result, appeal filed by the assessee is partly

ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune14 Nov 2025

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1778/Pun/2024

For Appellant: Shri Ajit Jain andFor Respondent: Shri Prakash L. Pathade

Section 144Section 144CSection 144C(8)Section 153Section 37(1)Section 92CSection 92D

provisions) (iii) Large expenditure by way of penalty or find for violation of any law for the time being in force (iv) High risk International Transactions (Entity reported in CbCR data) (TP Risk Parameter) 8. So far as issues relating to disallowance u/s.40A(7) of the Act (Gratuity provision ... find assessee furnished submissions and after considering the same no adverse inference was drawn. Ld. Assessing Officer (AO) further observed that there are certain international transactions entered into by the assessee namely 'Payment of Royalty for Trademark at Rs.1,35,33,495/- and Intra Group Services availed from

My Home Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 289/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-2019

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate A.V. RaghuramFor Respondent: : Dr. Narendra Kumar Naik, CIT (DR)

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

following effect: “10B. (1) For the purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction or a specified domestic transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— Page ... comparable uncontrolled transaction, or a number of such transactions, is identified; (ii) such price is adjusted to account for differences, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions which could materially affect the price

Deloitte Consulting India Projects Lp, Hyderabad vs. ADIT (Int Taxn)-1, Hyderabad

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

ITA 1386/HYD/2024[2021-22]Status: HeardITAT Hyderabad14 Nov 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1386/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) M/S. Deloitte Consulting Vs. Asstt. Director Of Income India Projects Lp, Tax (Int.Taxation)-1 Hyderabad Hyderabad Pan:Aadcd1272B (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ketan K. Ved, Ca राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/11/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Ketan K. Ved, CAFor Respondent: : Smt. U Mini Chandran, CIT(DR)

Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 92C

Accordingly, notice under section 143(2) of the Income Tax Act, 1961 (“the Act”) was issued to the assessee on 30.06.2022. Since there were international transactions entered into by the assessee with its Associated Enterprise (“AE”), the Learned Assessing Officer (“Ld. AO”) referred the matter to the Learned Transfer Pricing

Signode India Limited, Hyderabad vs. ACIT, Circle-3(1), Hyderabad

ITA 240/HYD/2023[2015-16]Status: DisposedITAT Hyderabad14 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 143(3)Section 144C(5)Section 32

ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited have erred in making the transfer pricing adjustment of INR 1,95,55,466 to the international transactions relating to manufacture and sale of Wheelchairs to Associated Enterprises ("AE"). 1.3. In the facts and circumstances of the case ... facts and circumstances of the case, the Ld. DRP and Ld. TΡΟ/ΑΟ have erred in considering receivables outstanding from AE as an international transaction and have erred in not accepting the contention of the Appellant that it does not fall within the purview of capital financing as stated under

Signode India Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 434/HYD/2021[2016-17]Status: DisposedITAT Hyderabad14 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 143(3)Section 144C(5)Section 32