“international transaction”

Accenture Solutions Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

In the result, the appeal is allowed as indicated above

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

filed by the assessee was picked up for scrutiny. In course of assessment proceeding, the A.O. having found that the assessee has entered into international transactions with its overseas Associated Enterprises (AE) made a reference to the Transfer Pricing Officer (‘TPO’ for short) to determine the ALP of the international

Garware Fulflex India Pvt Ltd, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

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

Bench: Smt. Beena Pillai () & Shri Om Prakash Kant ()

incorrectly not considering the analysis and documentation Erred in proposing an adjustment of INR 65,42,860 to the value of couple of international transactions of the Appellant by not considering the analysis and documentation maintained by the Appellant to determine the arm's length price ('ALP') of aforesaid international ... connection with interest on overdue receivables, the Ld. TPO and Ld. AO have erred in considering the said transaction as a separate international transaction warranting a separate analysis Erred and failed to appreciate that receivable/ payable resulting from the international transactions has been treated as closely linked transaction to other

M/S. International Specialty Products (India) Private Limited, Hyderabad vs. Circle 15(1)(2), Mumbai

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2012-13

scrutiny assessment. A reference u/s 92CA(1) of the Act was made for determination of arm's length price (ALP) in respect of international transactions undertaken by the assessee. Ld. TPO made the following adjustments in the Transfer Pricing Order: 3 International Specialty Products (India ... International Transaction Adjustment in Rs. 1 Provision of ITES 1,20,93,662/- 2 Contract R&D 72,32,832/- Total TP Adjustments 1,93,26,494/- 4.1. The comparables proposed by the assessee and ld. TPO for the R&D segment are given in the table below: Comparables selected

J P Morgan Services India Pvt Ltd, Mumbai vs. DCIT Circle 2(2)(1), Mumbai

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

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalj P Morgan Services India Private Limited Tower A Blk 9, Tower B Blk 10, Tower C Blk 11, Nirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai Suburban, ............... Appellant 400063. Pan : Aabcd0503B V/S Deputy Commissioner Of Income-Tax, Circle 2(2)(1), ……………… Respondent Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai-400020. Assessee By : Shri Fenil Bhatt Revenue By : Ms. Neena Jeph, Cit.Dr

Transfer Pricing DC/ACIT TP 2(3)(1) ('Ld. TPO') and making an adjustment of INR 8,173,090,919/- in relation to the international transaction of provision of back office support services in the nature of information technology ('IT") Support Services and IT enabled services ('ITeS') to the associated enterprises ... TPO/Hon'ble DRP erred in not excluding certain companies from the final set of comparable(s), which are functionally dissimilar to the Appellant's international transaction of provision of back office support services in the nature of IT Support services and IT enabled services. 9. On the facts

Addl CIT Ltu, Mumbai vs. Bajaj Holding & Investment Ltd ( Foremerly Known As Bajaj Auto Ltd), Mumbai

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Assessing Officer in making an addition of Rs. 28,13,755/- under section 92CA(3) of the Act in respect of the international transaction of export of machinery and tools. The appellant hereby reserves the right to add, to alter or amplify the above grounds of appeal ... Counsel submitted that, the assessee is engaged in manufacturing of two and three dealers. It is submitted that the assessee entered into international transaction of export of ITA No. 5510 & 5652/Mum/2012; 39 A.Y. 2007-08 Bajaj Holding & Investment Ltd. (Formerly Known as Bajaj Auto Ltd.) machinery and tools with

ACIT-8(1)(1), Mumbai vs. Reliance Life Sciences Pvt. Ltd., Navi Mumbai

Bench: Smt. Beena Pillai & Shri Girish Agrawal

course of assessment proceedings, a reference was made u/s.92CA(3) to the transfer pricing officer (TPO) to compute arm's length price (ALP) of international transactions undertaken by the assessee with its AEs. In the order passed by ld. TPO u/s.92CA(3), an upward adjustment of Rs.5 ... interest on loan outstanding to satisfy the arm's length principle. He thus, rejected the submissions made by the assessee. According to him, international transaction representing nil interest on outstanding loan to its AE is not at arm's length price within the meaning of section 92C(3)(a) r.w.r

Shree Arihant Gems, Mumbai vs. Income Tax Officer-19(3)(1), Mumbai

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

claimed excessive loss, deduction, allowance or relief in the return; [(ba) where the assessee has failed to furnish a report in respect of any international transaction which he was so required under section 92E;] (c) where an assessment has been made, but— (i) income chargeable to tax has been underassessed

Rolta India Ltd. Through Dr. Mamta Binani, Rp., Mumbai vs. Dy.Commissioner of Income Tax Central Circle -1(1), Mumbai

In the result, appeal of the assessee in ITA No

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.3563/Mum/2024 "नधा"रण वष" / Assessment Year :2020-21 Rolta India Ltd. Through Dr. Mamta Binani, Rp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent आयकर अपील सं. / Ita No.2737/Mum/2023 "नधा"रण वष" / Assessment Year :2018-19 Rolta India Ltd. Through Dr. Mamta Binani, Irp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant M/S. Rolta India Ltd. बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent

rejected the contention of the assessee that the adjustment is not required in this regard, since it is not an international transaction. However, the DRP directed the TPO to recompute the interest by taking into consideration the credit period granted by the assessee in the invoices. Pursuant ... follows: “37. Once we have held that the transaction between theassessee and AE was in foreign currency with regard toreceivables and transaction was international transaction,then transaction would have to be looked upon by applyingthe commercial principles with regard to internationaltransactions and accordingly proceeded to take into accountinterest rate

Rolta India Ltd, Mumbai vs. DCIT, Central Circle-1(1), Mumbai

In the result, appeal of the assessee in ITA No

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.3563/Mum/2024 "नधा"रण वष" / Assessment Year :2020-21 Rolta India Ltd. Through Dr. Mamta Binani, Rp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent आयकर अपील सं. / Ita No.2737/Mum/2023 "नधा"रण वष" / Assessment Year :2018-19 Rolta India Ltd. Through Dr. Mamta Binani, Irp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant M/S. Rolta India Ltd. बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent

rejected the contention of the assessee that the adjustment is not required in this regard, since it is not an international transaction. However, the DRP directed the TPO to recompute the interest by taking into consideration the credit period granted by the assessee in the invoices. Pursuant ... follows: “37. Once we have held that the transaction between theassessee and AE was in foreign currency with regard toreceivables and transaction was international transaction,then transaction would have to be looked upon by applyingthe commercial principles with regard to internationaltransactions and accordingly proceeded to take into accountinterest rate