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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

Novateur Electrical and Digital Systems Pvt Ltd., Mumbai vs. Asst CIT 10(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed and that by the Revenue is dismissed

ITA 944/MUM/2020[2012-13]Status: DisposedITAT Mumbai25 Aug 2025AY 2012-13

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Nikhil Tiwari and Shri Lekh Mehta, CAsFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)Section 32Section 92CSection 92C(2)

Rs.69,68,351/-. The return was revised on 28.11.2013 reporting total loss at Rs.9,60,84,412/-. During the year, assessee had entered into international transactions with Associate Enterprises (AEs) in respect of which ld. Assessing Officer made a reference u/s.92CA(i) to the Transfer Pricing Officer (TPO) for determination ... incorporated by the ld. Assessing Officer while passing the final assessment order, details of which are tabulated below: Nature of international transactions Amount in INR Method used for benchmarking Import of raw material, samples and 52,72,65,801 TNMM spare parts Import of finished goods

Dy CIT 10(3)(1), Mumbai vs. M/S Novateur Electricals and Digital Systems Pvt Ltd., Mumbai

In the result, appeal of the assessee is partly allowed and that by the Revenue is dismissed

ITA 1189/MUM/2020[2012-13]Status: DisposedITAT Mumbai25 Aug 2025AY 2012-13

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Nikhil Tiwari and Shri Lekh Mehta, CAsFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)Section 32Section 92CSection 92C(2)

Rs.69,68,351/-. The return was revised on 28.11.2013 reporting total loss at Rs.9,60,84,412/-. During the year, assessee had entered into international transactions with Associate Enterprises (AEs) in respect of which ld. Assessing Officer made a reference u/s.92CA(i) to the Transfer Pricing Officer (TPO) for determination ... incorporated by the ld. Assessing Officer while passing the final assessment order, details of which are tabulated below: Nature of international transactions Amount in INR Method used for benchmarking Import of raw material, samples and 52,72,65,801 TNMM spare parts Import of finished goods

ACIT, Circle- 9(1), New Delhi vs. Fis Global Business Solutions India Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue and CO of the assessee are partly allowed as above for statistical purposes

ITA 372/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Aug 2025AY 2009-10

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishra

financial service providers, retailers, network & gateway remarketers and e-commerce providers. 4.1 During the relevant year, the assessee has entered into the following international transactions with its AEs: S.No. Nature of the International Transactions Amount (in INR) 1. Provision of software development services 72,15,59,571/- 2. Provision ... rate @6.00%) 1,14,50,676/- 4.2 The Assessing Officer (‘AO’) made reference to the Transfer Pricing Officer (‘TPO’) for benchmarking the above-mentioned international transactions with its AEs. The assessee has adopted the Transactional Net Margin Method (‘TNMM’) on segmental basis as the most appropriate method for both segments

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

In the result, appeal of the Assessee is partly allowed

ITA 975/HYD/2024[2020-21]Status: DisposedITAT Hyderabad22 Aug 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Sriram SeshadriFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(1)Section 144C(5)Section 153Section 195Section 234ASection 40Section 92C

proceedings, a reference was made to the Transfer Pricing Officer [in short “TPO”] for determining the Arm's Length Price [in short “ALP”] of international transactions of the appellant-company with it’s Associated Enterprises [in short “AE”]. The TPO vide it’s order u/sec.92CA(3) of the Income ... Therefore, imputing interest on overdue receivables is not warranted when the appellant- company has carried-out an entity level TNMM to calculate ALP of international transactions, particularly, when the working capital adjustment have already been made by the appellant-company. In this regard, he relied upon the decisions

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

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

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

have erred, in law and on facts, in re-computing the arm's length price ('ALP') under the 'Other Method" for the international transaction relating to interest paid on CCDs and making an inadvertent downward adjustment of INR 133,71,83,173 thereby, restricting the amount of carried forward interest ... Appellant using Comparable Uncontrolled Price (CUP) method; and 4.1.2 Adopting 'Other method' as the most appropriate method for determining the ALP for the international transaction in relation to payment of interest on CCDs issued during FY 2019-20, FY 2018-19 and FY 2017-18. 4.2 Recharacterizing a debt instrument

Red Hat India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax/ITO/ Circle 15(3)(1), Mumbai

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

ITA 2442/MUM/2022[2018-19]Status: DisposedITAT Mumbai22 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Arun Khodpiaassessment Year : 2018-19 Red Hat India Private Limited, Asst. Commissioner Of A-201, Supreme Business Park, Income Tax/Income Tax Officer, Supreme City, Vs. Circle-15(3)(1), Hiranandani Gardens, Mumbai. Powai, Mumbai-400076. Pan : Aabcr7097N (Appellant) (Respondent) For Assessee : Shri Ajit Jain, For Revenue : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 13-08-2025 Date Of Pronouncement : 22-08-2025 O R D E R Per Amit Shukla, J.M : The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Dated 27/07/2022 Passed By The Acit, Circle 15(3)(1) Mumbai, U/S 144C(13) For The A.Y. 2018-19, In Pursuance To The Directions Issued By The Dispute Resolution Panel-2, Mumbai-2, Dated 15/06/2022 U/S 144C(5).

For Appellant: Shri Ajit JainFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 144C(13)Section 144C(5)

subscription and providing Red Hat products related training and consulting services to customers in Indian subcontinent. 4. Ld.TPO noted that, following were the international transactions of assessee with its AE’s during the year under consideration: Method used for S.No. Nature of International Transaction Amount (in INR) determining ... employees 2 Red Hat India Private Limited 5. Ld. TPO has made adjustment amounting to INR 44,67,17,609 to the value of international transactions pertaining to the following segments: S.No. Issue Amount (in INR) Payment of Royalty and Service 1 36,38,47,496 Fees (Subscription Segment) Payment

Mondelez India Foods Pvt. Ltd. (Formerly Known As Cadbury India Ltd.), Mumbai vs. ACIT, Range 5 (1)(2), Mumbai

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

ITA 7269/MUM/2019[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.7269/Mum/2019 निर्धारण वर्ष / Assessment Year :2015-16 M/S Mondelez India Foods Private Limited (Formerly Known As Cadbury India Limited), Mondelez House, Unit No.2001, 20Th Floor Tower-3 (Wing C) India Bulls Finance Centre), Parel, Mumbai-400 013 Pan : Aaac0460H ........अपीलार्थी / Appellant बनाम / V/S. The Assistant Commissioner Of Income-Tax, Range-5(1)(2), Mumbai, Aayakar Bhavan, M.K. Road Mumbai-400 020 ......प्रत्यर्थी / Respondent Assessee By : Shri J.D. Mistri, Sr. Advocate Shri Hiten Chande Revenue By : Shri Pankaj Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing :18.08.2025 घोषणा की तारीख / Date Of Pronouncement : 22.08.2025

For Appellant: Shri J.D. Mistri, Sr. AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 115JSection 143(3)Section 144C(1)Section 144C(5)Section 14ASection 234C

duly served on the assessee. A reference tothe Transfer Pricing Officer (TPO) was made in order to determine the arm'slength price of the international transactions, the assessee is having with itsAssociated Enterprises (AE). The TPO, vide order dated 30.10.2018 proposed atotal adjustment of Rs.319 ... incurred for marketing assessee"s own products and the payment was made to third parties in India. Therefore, it is outside the purview of international transaction as defined under section 92B of the ACT. As could be seen, the Transfer Pricing Officer ignoring the submissions made by the assessee

Stryker India Private Limited, New Delhi vs. ACIT, Circle-22(2), New Delhi

In the result, the appeal of the assessee is allowed as indicated above

ITA 2449/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Aug 2025AY 2018-19

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalstryker India Private Limited Assistant Commissioner C-5, Sda Commercial Complex, Of Income Tax, New Delhi-110016. Vs. Circle-22(2), New Delhi. Pan-Aaecs2513F (Appellant) (Respondent)

Section 92C

AO/Ld. Transfer Pricing Officer (Ld. TPO), erred in enhancing the income of the Appellant by INR 1,67,29,006 with regard to international transactions pertaining to provision of Marketing Support Services by 2.1 not accepting the economic analysis undertaken by the Appellant in accordance with provisions ... trade receivables of the Appellant and in doing so grossly erred in: 4.1 treating the outstanding receivables from Associated Enterprises (AEs) as a separate international transaction and re-characterising the outstanding receivables as loan advanced to AE by the Appellant; and 4.2 without prejudice to the above, disregarding that outstanding

M/S Kohinoor Foods Ltd., Delhi vs. ACIT, New Delhi

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1549/DEL/2016[2011-12]Status: DisposedITAT Delhi22 Aug 2025AY 2011-12

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

there before the Lower authorities. The case of the assessee was thereafter selected for scrutiny and the matter was referred to the TPO, observing international transactions between the assesse and its AEs abroad. Thereafter, the Ld. TPO made certain adjustments with respect to the international transactions and sent back ... purpose of making adjustment on account of Kohinoor Foods Ltd. vs. ACIT interest without appreciating that the opening balance cannot be treated as international transaction for the relevant assessment year. He referred page Nos. 135 to 148 of the order of the ld. TPO, page

M/S Kohinoor Foods Ltd, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1900/DEL/2015[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

there before the Lower authorities. The case of the assessee was thereafter selected for scrutiny and the matter was referred to the TPO, observing international transactions between the assesse and its AEs abroad. Thereafter, the Ld. TPO made certain adjustments with respect to the international transactions and sent back ... purpose of making adjustment on account of Kohinoor Foods Ltd. vs. ACIT interest without appreciating that the opening balance cannot be treated as international transaction for the relevant assessment year. He referred page Nos. 135 to 148 of the order of the ld. TPO, page

Prithvi Information Solutions Limited, Hyderabad vs. ACIT, Circle-16(2), Hyderabad

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

ITA 47/HYD/2017[2010-11]Status: DisposedITAT Hyderabad20 Aug 2025AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali MohanRao, C.AFor Respondent: Shri Narender Kumar Naik
Section 143(3)

assessee was selected for scrutiny and notice under section 143(2) of the Act was issued on 19.09.2011. In view of involvement of international transactions, the matter was referred to the Learned Transfer Pricing Officer (“Ld. TPO”) under section 92CA of the Act for determining the arm’s length price ... submitted that the assessee had adopted the Cost Plus Method (“CPM”) as the Most Appropriate Method (“MAM”) for benchmarking of its international transaction relating to SDS. However, the Ld. TPO rejected the CPM and applied the Transactional Net Margin Method (“TNMM”) as MAM. Inviting our attention to page no.11

Assistant Commissioner of Income Tax Ltu Circle 1 Chennai, Chennai vs. Carborundum Universal Limited, Chennai

ITA 48/CHNY/2025[2017-18]Status: DisposedITAT Chennai20 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

For Appellant: Shri R.Vijayaraghavan, AdvocateFor Respondent: Shri P.K.Senthil Kumar, Addl. CIT

assessee in respect of guarantee and comfort letter issued to the creditors of the Associated concern. The TPO found that the Assessee had an international transaction with its Associated Enterprises (AE) by way of providing letters of guarantee/comfort to the creditors of the AE. TPO concluded that the appellant should ... adopted by the Assessing Officer. On further appeal before us, the AR of the Assessee submitted that provision of guarantee is not an international transaction and hence no adjustment can be made. However, in view of the decision of the Madras High Court in the case of Redington India Limited

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

In the result, appeals of the assessee are partly allowed

ITA 3619/DEL/2018[2011-12]Status: DisposedITAT Delhi20 Aug 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

referred the matter to the Transfer Pricing Officer (TPO) with regard to the determination of Arm’s Length Price (ALP) involving the international transaction said to have been undertaken by the respondent/assessee. The TPO opined, that an upward adjustment amounting to Rs.56,30,78,638/- would have to be made

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

Indian Metals & Ferro Alloys Ltd. (hereinafter referred to as the "the assessee") for the computation of arm’s length price in relation to international transaction detailed in the audit report in Form No. 3CEB was received through online portal on 16.09.2022. 2.0 Subsequently, an order under section 92CA

JCIT(OSD) I/C. of DCIT -1(3)(1), Mumbai vs. Zt Systems India Private Limited, Mumbai

In the result, appeal of the revenue is dismissed as per our aforesaid observations

ITA 1729/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Aug 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.1729/Mum/2025 "नधा"रण वष" / Assessment Year :2016-17 The Jt. Commissioner Of Income Tax (Osd), I/C. Dcit-1(3)(1), Mumbai (M.H.)

For Appellant: Shri Ajit JainFor Respondent: Shri Aditya Rai, Sr. DR
Section 115Section 115ASection 143(3)Section 2(22)(a)Section 201Section 206C(7)Section 92C

observed that transfer pricing provisions laid out in the Act are in the nature of machinery or computational provisions and that income arising from international transactions between associated enterprises must be income under the Act and that such income must be chargeable under the charging provisions (i.e. Sections ... No.871 /2014). 7. Decision: 7.1 Ground Nos.1 & 2 - Both grounds relates to addition on account of adjustment of Arms-length Price in relation to international transaction with Associated Enterprises ('AEs') amounting to Rs. 6,39,60,000 From the above facts, it is clear that the matter under consideration

India Japan Lighting Private Limited, Chennai vs. Principal Commissioner of Income Tax - 4, Chennai

In the result, appeal filed by the assessee is allowed

ITA 1427/CHNY/2025[2021-22]Status: DisposedITAT Chennai18 Aug 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1427/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 V. M/S. India Japan Lighting Pvt. Ltd., The Pcit-4, No.1, Tiruvallur High Road, Chennai. Puduchatram B.O., Thirumazhisai, Tiruvallur-600 124. [Pan: Aaaci 2673 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 144BSection 263

CbCR (Country-by Country Reporting) data on the basis of annual return filed by large multi-nationals, during F.Y.2020-211 assessee company entered into International Transactions. Give details of all such International Transactions(both w.r.t. a) export of goods or providing services to foreign based entities and b) Import of goods ... cost and impairment of property, plant and equipment of Gujarat Plant due to Covid pandemic and economic slowdown in automobile sector. 15. Details of International Transaction Refer Annexure - 14 8. The assessee also filed Reconciliation of additions between FS and Tax audit as under: Summary of additions as per Income

Te Connectivity Services India Private Limited, Bangalore vs. DCIT Circle, 7(1)(1), Bangalore

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

ITA 1887/BANG/2024[2020-21]Status: DisposedITAT Bangalore18 Aug 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: S/Shri Sriram Sheshadri & Vinay Jain, CAsFor Respondent: Smt. Suganthamala T M, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 144CSection 40Section 92C

No.1887/Bang/2024 Page 2 of 14 assessed at Rs.29,19,047 making adjustment on account of arm’s length price [ALP] of international transaction at Rs.10,62,815 & variation in respect of disallowance of Rs.9,56,232. 2. The assessee is aggrieved and has preferred the appeal on the following ... Human Resource, customer support for TE group for which it is compensated on cost plus mark-up basis. 4. As assessee has entered into international transactions, reference u/s. 92CA was made after issuing notice u/s. 143(2) of the Act, which was approved by the PCIT and thereafter

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)
Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

major shareholder of Rubicon Group which operates out of India, USA and Canada. The case was selected for scrutiny for verification of large value international transactions. A reference was made by the AO to the TPO to compute the arm’s length price (ALP) u/s. 92CA ... relation to the international transactions and the specified domestic transactions undertaken by the assessee with its Associated Enterprises (AEs) during the year under consideration. Vide order dated 29.10.2023 u/s. 92CA(3) the TPO proposed total adjustment on account of ALP of Rs. 5,06,96,789/-. The assessee had adopted

Deputy Commissioner of Income Tax, Chennai vs. Ashok Leyland Limited, Chennai

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

ITA 2905/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Aug 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 143(2)Section 92B

duly served on the assessee. The AO noted from the perusal of Form 3CEB submitted by the assessee that the assessee company had International Transaction with AEs to the tune of Rs.744,24,38,759/-. Therefore, the case was referred to the TPO. Pursuant thereto, the TPO noted that ... tune of Rs.356,17,22,311/-. So, the TPO show caused the assessee as to why adjustment towards Arms Length Price (ALP) of this International Transaction shall not be made. Pursuant to which, the assessee company submitted that it has not charged any service fees from the Associated Enterprises

M/S T vs. Motor Company Limited, Chennaivs.ACIT Corporate Circle 3 (1), Chennai

ITA 2405/CHNY/2019[2014-14]Status: DisposedITAT Chennai13 Aug 2025AY 2014-14

Bench: Shri Aby T Varkey & Shri Amitabh Shukla

Section 92C(2)

Counsel for the assessee informed that the appellant company is engaged in the business of manufacturing of two wheeler and other vehicles. The international transactions of the appellant assessee was subjected to TP verification whereby the Ld.TPO made impunged addition of Rs.14,78,78,398/-. Brief factual matrix