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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

Deputy Commissioner of Income Tax Circle 8 1 (Incharge), Hyderabad vs. Virtusa Consulting Services Private Limited, Tamil Nadu

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2632/CHNY/2024[2013-14]Status: DisposedITAT Chennai14 Nov 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

facts by making an upward adjustment of Rs 35,14,000 to the arm’s length price (‘ALP’) of the Appellant’s international transactions entered into with associated enterprises (AEs). 3. For international transactions with Polaris Software Lab Limited, United Kingdom (‘Polaris UK’): The Learned CIT(A) have erred ... partly allowed. 12. Issue No 5: Transfer pricing Issue- Ground Nos 2-4 in IT(TP)A No.42/Chny/2024 12.1 The assessee for the international transactions with Category A subsidiaries of the assessee (Category A subsidiaries are the subsidiaries who operate as captive service providers who undertake lesser functions and bear

Assistant Commissioner of Income Tax, Hyderabad vs. Virtusa Consulting Services Private Limited, Chennai Tamil Nadu

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2631/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

facts by making an upward adjustment of Rs 35,14,000 to the arm’s length price (‘ALP’) of the Appellant’s international transactions entered into with associated enterprises (AEs). 3. For international transactions with Polaris Software Lab Limited, United Kingdom (‘Polaris UK’): The Learned CIT(A) have erred ... partly allowed. 12. Issue No 5: Transfer pricing Issue- Ground Nos 2-4 in IT(TP)A No.42/Chny/2024 12.1 The assessee for the international transactions with Category A subsidiaries of the assessee (Category A subsidiaries are the subsidiaries who operate as captive service providers who undertake lesser functions and bear

Virtusa Consulting Services Pvt. Ltd., Chennai vs. DCIT, CC-5(2), Chennai

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2262/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

facts by making an upward adjustment of Rs 35,14,000 to the arm’s length price (‘ALP’) of the Appellant’s international transactions entered into with associated enterprises (AEs). 3. For international transactions with Polaris Software Lab Limited, United Kingdom (‘Polaris UK’): The Learned CIT(A) have erred ... partly allowed. 12. Issue No 5: Transfer pricing Issue- Ground Nos 2-4 in IT(TP)A No.42/Chny/2024 12.1 The assessee for the international transactions with Category A subsidiaries of the assessee (Category A subsidiaries are the subsidiaries who operate as captive service providers who undertake lesser functions and bear

Fil India Business and Research Services Private Limited, Delhi vs. Assessment Unit, Income-Tax Department, Delhi

In the result, appeal of the assessee is partly allowed

ITA 3245/DEL/2024[2020-21]Status: DisposedITAT Delhi14 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2020-21] Fil India Business & Research Vs Assessment Unit Services Pvt. Ltd., Private Studio- Income Tax Ncra/Ac/Ps/00/010B, Ground Department, Delhi Floor, Worldmark 1, Asset Area 11, Aerocity, Hospitality District, Indira Gandhi International Airport, Delhi-110037. Pan-Aabcf1572C Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Shri Shitiz Bansal, Ar Respondent By Shri Dharm Veer Singh, Cit Dr Date Of Hearing 18.08.2025 Date Of Pronouncement 14.11.2025 Order

Section 143(3)Section 920Section 92C(3)

AO/Ld. TPO erred in enhancing the income of the Appellant by INR 14,56,72,227/- by holding that the Appellant's international transactions pertaining to provision of Research Support Services Segment do not satisfy the arm's length principle envisaged under the Act and in doing so have grossly ... raised by the assessee are with 5. respect to the transfer pricing adjustment made of INR 1,45,67,277/- on international transactions related to research support segment. 6. Ld.AR for the assessee submits that Ld. DRP vide its para No. 4.2.12.1, has directed the AO/TPO to re-verify

Pcl Foods Pvt. Ltd., Gurgaon vs. Addi CIT, National E- Assesment Centre, New Delhi

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

ITA 442/DEL/2021[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

Section 143(3)Section 92C

case was selected for Complete Scrutiny assessment under the E-assessment Scheme, 2019 on the following issues: -- I. Depreciation Claim II. Investments/advances/loans III. International transaction(s) 4. In this case, a reference dated 01.11.2018 was made to the Transfer pricing Officer (TPO) under Section 92CA ... ward 19(2), New Delhi to determine the Arm’s length price in respect of international transactions undertaken by the assessee company with its Associates Enterprises. The TPO noted that the assessee had entered into international transactions with the following group entities Sr. Name of the Group Nature of Brief

Applexus Technologies Private Limited, Trivandrum vs. DCIT, Kottayam

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

assessment proceedings reference was made by the Assessing Officer to the Transfer Pricing Officer (TPO) for determination of Arm’s Length Price of the International Transactions undertaken by the Assessee with its Associated Enterprises (AEs) during the relevant previous year. Vide Order, dated 05/10/2023, the TPO proposed upward transfer pricing ... undertaken a comprehensive & methodical search process, while carrying out the benchmarking analysis using the publicly available database. The analysis of comparability of international transactions with uncontrolled transactions involves certain amount of subjectivity. However, differences in the benchmarking approach adopted by the Assessee and by the TPO could not lead

M/S.Ibs Software Services P. Ltd, Trivandrum vs. The DCIT, Trivandrum

ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

scrutiny through CASS. During the assessment proceedings, it was noticed from the audit report in Form 3CEB that the Assessee had entered into International Transactions amounting to INR.2,34,83,13,172/- with its Associated Enterprises. The case of the Assessee was referred to the Transfer Pricing Officer (TPO) under ... Section 92CA of the Act for determination of the Arm's Length Price (ALP) in relation to the said international transactions. TPO passed order, dated 28/10/2016, under Section 92CA(3) of the Act proposing an upward transfer pricing adjustment of INR.31,09,52,334/-. The Assessing Officer passed the Draft

Abhay Chordia, Jaipur vs. The ACIT, Jaipur

In the result the appeal filed by the assessee is allowed

ITA 1121/JPR/2025[2017-18]Status: DisposedITAT Jaipur12 Nov 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT a
Section 143(1)Section 143(3)Section 250Section 68

contra, such amendment has resulted into increases in tax burden of the assesses. 8. Section 92B of the ITA setting the meaning of 'International Transaction' was introduced by Finance Act, 2001 w.e.f. 01/04/2002. Subsequently, an explanation was added to section 92B, increasing the scope of “international transaction” by Finance

Precision Camshafts Limited, Pune vs. DCIT Circle 1, Solapur

In the result, appeal of the assessee is partly allowed

ITA 2744/PUN/2024[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 143(3)Section 144BSection 144C(1)Section 144C(5)Section 153Section 92B

facts and in the circumstances of the case and in law, the Ld. AO /Ld. TPO has erred in proposing TP adjustment to the international transaction of corporate guarantee amounting to INR 21,46,000 to the total income by rejecting TP analysis conducted by the Appellant. 2. Corporate Guarantee ... international transaction On the facts and in the circumstances of the case and in law, while erred in arriving at arm’s length price of corporate guarantee provided by the Appellant, the Ld. AO/Ld. TPO has erred in the following - ignored the fact that the corporate guarantee provided to • subsidiary

Highradius Technologies Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad

ITA 436/HYD/2024[2020-21]Status: HeardITAT Hyderabad12 Nov 2025AY 2020-21

Bench: Us:

Section 143(1)Section 143(3)Section 144B

impugned order on the following grounds of appeal before us: “1. Erroneous transfer pricing adjustment of INR 10,58,23,162 in respect of international transaction of provision of software development and support services 1.1. The learned AO erred, on the facts and circumstances of the case ... adopted by the Appellant in its TP study report and applying additional filters and proceeded to undertake a fresh search for benchmarking the said international transaction of SOS services. 1.4 The learned AO/TPO erred in law and in facts in rejecting the following comparable companies accepted by the Appellant

Sony India Private Limited, Delhi vs. ACIT Circle 22(2), Delhi

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

ITA 3851/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi12 Nov 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roysony India Private Limited, Vs. Acit, Circle 22 (2), A – 18, Mohan Cooperative Indl. Area, New Delhi. Mathura Road, New Delhi – 110 044. (Pan :Aabcs1571Q) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 23.09.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appealpreferred By The Assesseeis Directed Against The Assessment Order Dated 30.07.2024Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144Bof The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020- 21Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)

multiple transfer pricing adjustments by subjecting the same business and resultant profits to multiple tests under different methods and PLIs, on pretext of different international transactions. Transfer Pricing adjustment in respect of transaction of payment of royalty: 4. Impugned order erred in law and in facts in considering ... length price of international transaction of payment of royalty as NIL: 4.1 Ld. DRP has erred in upholding the adjustment by relying on its directions for AY 2015-16 despite being intimated that the matter has been decided in favour of the Appellant by the Tribunal

M/S. Ambattur Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-1(1), Chennai

ITA 2601/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Respondent: Shri. R. Vijayaraghavan, Advocate
Section 50CSection 56(2)(vii)

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Concur Technologies (India) Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle 2(2)(1), Bangalore

Appeal of the assessee is partly allowed as indicated above

ITA 2550/BANG/2024[2021-22]Status: DisposedITAT Bangalore11 Nov 2025AY 2021-22

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

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru
Section 144Section 144BSection 144C

total income of the Appellant on account of adjustment in the arm's length price ("ALP") for international transactions entered by the Appellant with its associated enterprises ("AEs") as follows: 2.1. INR 18,049,387 in respect of provision of information technology ("IT") support services/ software development ("SWD") services ... corresponding Rules, conducting a fresh economic analysis for the determination of the ALP and holding that the Appellant's impugned international transactions are not at arm's length. 5. The learned TPC/ AO erred in law and in facts by erroneously treating 'rates and taxes, bad debts, provision

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

In the result appeal filed by the assessee is partly allowed

ITA 704/BANG/2023[2019-20]Status: DisposedITAT Bangalore11 Nov 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 115Section 143Section 144BSection 144CSection 234DSection 37Section 92C

refunded. As per ground No. 6 the assessee challenges the treatment of outstanding overdue receivable from its associated enterprises is considered as a separate international transaction and therefore the notional interest charged thereon of ₹ 65,234,694 cannot be considered as an international transaction and further it cannot be used ... should have been computed based on Euribor. As per ground No. 7 the assessee challenges the computation of the arm's-length price of international transaction of distribution segment challenging some of the filters, some of the comparable selected by the learned TPO and computation of margin in case

Ecoenergy Insights Ltd ( Formerly Known As Chubb Alba Control Systems P.Ltd), New Delhi vs. DCIT, Circle-4(2), New Delhi

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

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

last 28 years in India. During assessment proceedings, the AO observed from the books of account and financial records that assessee has undertaken international transactions. In view of the above, reference u/s 92CA (1) of the Act after obtaining approval from the competent authority was made ... reference, issued notice u/s 92CA of the Act and observed that the assessee has reported following international transactions in the form 3CEB :- Sl. No. Nature of transaction Method applied Amount (INR) 1 Purchase of electric security RPM 82495380 equipment/systems 2 Availing of support services TNMM 267389174 3 Receipt of Subvention

Addl.CIT, New Delhi vs. Makemytrip (India) Pvt. Ltd., Gurgaon

In the result, Cross Objections of the assessee is allowed

ITA 5384/DEL/2017[2007-08]Status: DisposedITAT Delhi10 Nov 2025AY 2007-08

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं. 5384 & 5385/िद"ी/2017(िन.व. 2007-08 & 2008-09)

For Appellant: Dr. Rakesh Gupta, & Shri Somil AgrawalFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 144CSection 147Section 148Section 40

record has reopened the 4 ITA Nos.5384 & 56385/DEL/2017 (A.Y.2007-08 & 2008-09) CO Nos. 48 & 47/Del/2017 assessment. The assessee in Form 3CEB has disclosed international transaction of reimbursement of expenses to the tune of Rs.3,60,01,993/-. The same was duly accepted by the Transfer Pricing Officer and the Assessing ... filed return of income declaring total income as NIL. Along with return of income, the assessee had filed report in Form 3CEB relating to International Transactions. In Form 3CEB, the assessee inter-alia declared reimbursement of expenses amounting to Rs.3,60,01,993/-. The case was referred to the Transfer

ACIT 5(1)(1), Mumbai vs. Dharmanandan Diamonds Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3615/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassistant Commissioner Of V/S. Dharmanandan Diamonds Income Tax – 5(1)(1) बनाम Pvt. Ltd., Fc 7081 7082, Room No. 568, 5Th Floor, Bharat Diamond Bourse, G- Aaykar Bhavan, Churchgate, Block, Bandra Kurla Complex, Mumbai – 400 020, Bandra (East), Mumbai – Maharashtra 400 051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccd6676J Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Rajiv Shah, ARFor Respondent: Ms. Neena Jeph, (CIT-DR)
Section 271GSection 92Section 92D

holding that the assessee had made substantial compliance, failing to note that under TNMM adopted by the assessee, the profit of the international transaction has to be furnished, whereas the assessee has only furnished the entity level margins which consists of overall profits on AE AMD significant non-AE transactions ... during TP proceedings and penalty u/s 271G was initiated. Subsequently, the TPO levied penalty u/s 271G at the rate of 2% of international transactions amounting to Rs. 97,48,36,693/-. 4. In the subsequent appeal, the ld.CIT(A) observed that the TPO had called upon the assessee to furnish

Aam India Manufacturing Corporation Private Limited, Ahmednagar vs. Income Tax Officer, Ward 1, Ahmednagar

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

ITA 1205/PUN/2025[2020-21]Status: DisposedITAT Pune31 Oct 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Saurabh KulkarniFor Respondent: Shri Amol Khairnar
Section 139(1)Section 143(1)Section 270ASection 274Section 41(1)

BL06.01 High Liabilities as compared to low income/receipt. 4 BE12.03 Large business loss set off against other heads of income. 5 TP12.01 High risk International Transactions (TP risk parameter) 6 CG02.01 Property sold at a consideration (shown in ITR) less than the value as per Stamp authority ... other relevant section) 7 TP03.01 International transactions in respect of lending or borrowing of money(TP Risk parameter) 8 BE02.01 Depreciation claimed at significantly higher rates/Large additional depreciation claimed. 3.1 Accordingly, notices u/s 143(2)/143(1) of the Act were issued and served upon the assessee, followed

Dgs Technical Services Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1095/HYD/2024[2021-22]Status: DisposedITAT Hyderabad31 Oct 2025AY 2021-22

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

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

declaring current year loss at Rs. 7,19,87,239/-. The assessee has filed Form 3CB along with the return of income and reported international transactions with its Associated Enterprises (A.E.), i.e., DGS INC., for providing structural steel engineering and detailing services at Rs. 51,16,93,970/-. The assessee ... OP/OC @ (-)0.02%. The assessee company has selected 8 comparable with the 35th percentile (-)1.05% and the 65th percentile of 3.52% and claimed that, its international transactions with its A.E. are at arm’s length price. 4. The case was selected for scrutiny, and during the course of assessment proceedings

DCIT Circle 3 3 1, Mumbai vs. Xoriant Solutions Private Limited, Mumbai

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

ITA 3676/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Pankaj R. Toprani and Ms. Krupa Shah, AdvocatesFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)

Reference was made to ld. TPO u/s 92CA(1) by the ld. Assessing Officer for computation of arms’ length price in relation to international transactions. According to ld. TPO, assessee has not properly applied the CPM. However, according to the assessee, since inception, it had been following CPM in respect