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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- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerly Ut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 533/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

Bench: Smt. Beenna Pillai () & Shri Omkareshwar Chidara ()

Section 37Section 92F

agreement with U.T.T. Networks Inc., U.K. for forwarding by air or sea of general commodities. 3. 1. The Ld.AO noted that the assessee had international transactions with its Associated Enterprises (AE's) beyond the threshold limit.Thusa reference was made to the Transfer Pricing Officer (Ld.TPO). The Ld.TPO called for economic ... orders passed by the Ld.CIT(A),the revenue preferred appeal before this Tribunal. 5. Ld.AR submitted, the Ld.TPO determined ALP of the international transaction by adopting one of the prescribed methods under the statute. It is submitted, that the Ld.TPO was not justified in determining

Deputy Commissioner of Income Tax- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerly Ut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 532/MUM/2025[2012-13]Status: DisposedITAT Mumbai30 Jul 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 37Section 92F

agreement with U.T.T. Networks Inc., U.K. for forwarding by air or sea of general commodities. 3. 1. The Ld.AO noted that the assessee had international transactions with its Associated Enterprises (AE's) beyond the threshold limit.Thus a reference was made to the Transfer Pricing Officer (Ld.TPO). The Ld.TPO called ... orders passed by the Ld.CIT(A), the revenue preferred appeal before this Tribunal. 5. The Ld.AR submitted, the Ld.TPO determined ALP of the international transaction by adopting one of the prescribed methods under the statute. It is submitted, that the Ld.TPO was not justified in determining

Swaran Nadhan Salaria, Mumbai vs. DCIT Central Circle 1(2), Mumbai

ITA 1055/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Jul 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(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 5. the amount of undisclosed income referred to in section 271AAB ... 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

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1050/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(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 5. the amount of undisclosed income referred to in section 271AAB ... 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

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1049/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(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 5. the amount of undisclosed income referred to in section 271AAB ... 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

Fedex Express Transportation and Supply Chain Services (India) Private Limited, Mumbai vs. ACIT 1(3)(1), Mumbai

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

ITA 4783/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 144Section 144BSection 144C(1)Section 144C(13)Section 92CSection 92C(3)

adjustment of INR 31.16,32,000/- in respect of the Appellant's margin earned in its outbound segment, in relation to the international transactions of availing outbound transportation and related services from the Associated Enterprise ('AE'). 3.2. The lower authorities erred in determining the arm's length margin in respect ... scrutiny and notices were issued to the assessee u/s.142(1) and 143(2) of the Act. 2.1 The Ld.AO noted that, assessee had international transaction with it is associated enterprise exceeding threshold limit. A reference was thus made to the Ld.TPO to determine arms length price of the international transactions

Irdeto Technology India Private Limited, Delhi vs. Assessing Unit, Income Tax Department, Delhi

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

ITA 5241/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Jul 2025AY 2021-22

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalirdeto Technology India Assessment Unit, Private Limited, Income Tax Department, 171, Somdutt Chambers-Ii, Vs. (Ld. Ao). Bhikaji Cama Place, New Delhi-110066, India Pan-Aabci3564M (Appellant) (Respondent) Assessee By Ms. Parul Girdhar, Ca Department By Shri S. K. Jadhav, Cit-Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 30/07/2025 O R D E R Per Prakash Chand Yadav, Jm: The Present Appeal Of The Assessee Is Arising Out From The Order Of Ld. Assessing Officer Dated 25Th September, 2024 Having Din No. Itba/Ast/S/143(3)/2024-25/1069101879(1) & Relates To Assessment Year 2021-22. 2. The Assessee Has Raised Five Grounds Of Appeal, Out Of Which Ground No.3,4,5 Are Consequential & Hence, Does Not Require Adjudication.

vide its order dated 29th August, 2024 has directed the TPO to consider certain filters, while selecting comparable for bench marking the international transaction. Thereafter, the TPO passed the order giving effect and thus, the AO passed the final assessment order, impugned before us. 6. At the outset

Urb India Bearing Factory and Trade Pvt. Ltd., New Delhi vs. ITO Ward 27(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 375/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jul 2025AY 2020-21

Bench: Shri C. N. Prasad & Shri M. Balaganeshurb India Bearing Factory Vs. Ito & Trade Pvt. Ltd. Ward-27(1), C/O Co Working Space New Delhi Management Private Limited, 3Rd Floor, Kushal House, 39 Nehru Place, Delhi-110019 (Appellant) (Respondent) Pan: Aabcu3023H Assessee By : Ms. Rano Jain, Adv Ms. Mansi Jain, Ca Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 16/07/2025 Date Of Pronouncement 30/07/2025

For Appellant: Ms. Rano Jain, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(13)Section 143(3)Section 144C(5)Section 92C

worldwide supplier of bearings and provides services in the rolling bearing business and is located in Romania. The assessee has reported the following international transactions of the company as per Form 3CEB:- SI. No. Nature of transaction Method applied Amount (in Rs.) 1. Sale of Traded goods TNMM

Uil Electronics India Private Limited, Gautam Budh Nagar vs. ACIT, DCIT, NFAC, Drp, Civic Center, New Delhi

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

ITA 3712/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jul 2025AY 2020-21

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

unit, which means the assessee does not have any transactions with non-associated enterprises for the year under consideration. The assessee has entered into international transaction with AEs; accordingly, a reference was made to the TPO, who after analyzing the TP study report of the assessee made an upward adjustment ... expenses to the tune of 2% of total sales and, hence, the approach of the TPO is not correct in the bench marking the international transaction. In simple word, it is the contention of the assessee is that R&D filter may kindly be provided. Similarly, the Counsel for assesse

Square Dotcom Provate Limited, Gurgaon vs. ACIT Circle-24(1), New Delhi

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

ITA 245/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jul 2025AY 2016-17

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalm/S Square Dotcom Private Asst. Commissioner Of Limited, Income Tax, 9Th Floor, Good Earth Business Vs. Circle-24(1), Bay, Sector-58, C.R. Building, Gurgaon, Harayan-122011 New Delhi. Pan-Aaucs8074R (Appellant) (Respondent) Assessee By Shri Prabhakar Kumar, Ca Department By Shri S. K. Jadhav, Cit-Dr Date Of Hearing 23/07/2025 Date Of Pronouncement 30/07/2025 O R D E R Per Prakash Chand Yadav, Jm: The Present Appeal Of The Assessee Is Arising Out From The Order Of Ld. Assessing Officer Dated 13Th February, 2021 Having Din No. Itba/Ast/S/143(3)2020-21/1030628110(1) & Relates To Asst. Year 2016-17. 2. At The Outset, Ld. Counsel For The Assessee Pointed Out That The Transaction Between Assessee & Its Ae’S Was Out Of The Purview Of International Transaction In As Much As The Assessee Has Only Issued Equity Share To Its Associated Enterprises (Ae), In Lieu Of The Share Capital Received From Ae. It Is The Contention Of The Assessee That This Transaction Does Not Have Any Bearing On The Profits Of The Company And, Therefore, It Is Out Of The Purview Of International Transaction & Hence, No Transfer Pricing Adjustment Can Be Made Qua This Transaction.

outset, Ld. Counsel for the assessee pointed out that the transaction between assessee and its AE’s was out of the purview of international transaction in as much as the assessee has only issued equity share to its associated enterprises (AE), in lieu of the share capital received from ... assessee that this transaction does not have any bearing on the profits of the company and, therefore, it is out of the purview of international transaction and hence, no transfer pricing adjustment can be made qua this transaction. 3. Per contra, Ld. CR relied pointed out that this plea

Guala Closures (India) Pvt. Ltd., Panaji vs. The Income Tax Officer, Ward-1(1), Panaji.

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

ITA 62/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Jul 2025AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.62/Pan/2017 (A.Y.2012-13 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Seasa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent

For Appellant: Shri.Nirajsheth. ARFor Respondent: Shri.Satish M .CIT DR
Section 115Section 143(3)Section 144C(5)

explanations in support of the return of income filed. The Assessing officer (A.O) on perusal of the financial statements found that the assesse has international transactions with its Associate Enterprises (AE) and therefore the matter was referred to the Transfer Pricing Officer (TPO) for determination of Arm’s Length Price ... information in support of ALP computed as per Form.no.-3CEB. Whereas, the assessee has submitted the details and documents relating to the international transactions with its Associate Enterprises(AE) and the basis of computation of ALP. On the disputed issue in respect of payment of management fees

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Aathmika Holdings Pvt Ltd, Chennai

In the result, the appeal of the Revenue stand dismissed and the

ITA 836/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivas, CIT
Section 132Section 139(1)Section 142(1)Section 143(2)Section 56(2)(x)Section 92C

Green Grid Group Pte Ltd., Singapore (in short ‘G3’). According to the AO, this transaction involving acquisition of shares from G3 qualified as an international transaction with an associated enterprise (AE) and therefore, made a reference to the Transfer Pricing Officer (TPO) u/s 92CA(2) of the Act, after obtaining

Portescap India Private Limited, Mumbai vs. DCIT Circle 2(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 6749/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153Section 92C(3)

TPO/Ld. DRP erred in making an adhoc disallowance of 50% of transaction value while determining the arm's length price of the Appellant's international transaction of payment of sales commission to its Associated Enterprise ('AE') Portescap S.A., Switzerland, resulting in a transfer pricing adjustment ... Appellant, wherein benchmarking approach using aggregated/combined Transactional Net Margin Method ("TNMM") has been adopted as the most appropriate method ('MAM') for benchmarking the subject international transaction; 3.2Determining arm's length price of international transaction of payment for sales commission to AE as 'Nil' for the 50% value

Teejay India Private Limited, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-5(1), Visakhapatnam

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

ITA 340/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Sri Darpan Kirpalani, AdvocateFor Respondent: Dr. Satyasai Rath, CIT(DR)
Section 142(1)Section 143(2)Section 143(3)Section 144C(5)Section 92C

annexure calling for relevant details. In the course of assessment proceedings, the Ld. AO noticed that Form 3CEB report of the assessee company had international transactions with its Associated Enterprises (AEs). Hence, a reference was made to the Transfer Pricing Officer u/s. 92CA(1) of the Act for the international ... interest rate on external commercial 4 Teejay India Private Limited vs. DCIT borrowings. The Ld. AR contended the treatment of notional interest receivable as international transaction. The Ld. AR further made submissions before the Ld. DRP in respect of disallowance of payment of royalty to the AE in relation

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

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

ITA 1376/HYD/2024[2021-22]Status: DisposedITAT Hyderabad25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri H. Srinivasulu, C.AFor Respondent: Dr. Sachin Kumar, SR-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, ITA No.1376/Hyd/2024 3 without appreciating that the principal international transactions resulting in such receivables have been found to be at arm’s length ... return of income for the Assessment Year 2021–22 on 14.03.2022, declaring a total income of Rs.183,55,39,089/-. In view of the international transactions involved during the year under consideration, for determination of Arm’s Length Price (“ALP”), the case was referred to Learned Transfer Pricing Officer

M/S. Laxmi Organic Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

ITA 4782/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Percy Pardiwala, Sr. Advocate andFor Respondent: Ms. Neena Jeph, CIT DR
Section 144C(5)Section 80I

case, and in law, the learned Assessing Officer wholly erred in making addition on account of "Arm's length price in relation to international transactions with associated enterprises" amounting to "Rs 83,66,17,206", whereas, on the facts of this case, no additions in respect of "arm's length ... putting assessee to the notice), the learned Assessing Officer thus erred in law in making arm's length price adjustments in respect of alleged international transactions in the computation of income. Arm's length Price (ALP)/ Transfer Pricing (TP) Adjustments -Without prejudice grounds, on merits of the purported ALP adjustments

ACIT - 14(2) (2), Mumbai vs. Pfizer Ltd, Mumbai

ITA 1497/MUM/2018[2005-06]Status: DisposedITAT Mumbai25 Jul 2025AY 2005-06

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) Acit-14(2)(2) M/S. Pfizer Limited 461, 4Th Floor The Capital, 802/1901 Aayakar Bhavan Vs. Plot No. C-70, G Block M.K. Road Bandra Kurla Complex Mumbai-400 020. Bandra East, Mumbai 400 0051. Pan : Aaacp3334M Appellant Respondent

For Appellant: Shri Nihar Ranjan SamalFor Respondent: Shri Vishal Kalra

selected by the Respondent for benchmarking the provision of CSMM support services and applied contract Research & Development ("R&D") companies for benchmarking the said international transaction. Accordingly, computed an arm's length margin of 23.76%. Further, the TPO considered the Assessee's operating margin earned from the provision of CSMM ... cost) as against the comparables operating margin of 23.76%. Accordingly, an adjustment of INR 2,66,54,778 was made in respect of the international transaction of provision of CSMM activity of the respondent. The Ld. CIT(A) relying on the order passed by his predecessor in Respondent

Convergys India Services Private Limited, Gurgoan vs. DCIT Circle-4(2), New Delhi

In the result, the appeal of the assessee is dismissed as discussed above

ITA 1412/DEL/2023[2014-15]Status: HeardITAT Delhi25 Jul 2025AY 2014-15

Bench: Prakash Chand Yadav & Shri Manish Agarwal[Assessment Year : 2014-15] Convergys India Services Private Vs Dcit, Limited, Industrial Plot N-243, Circle-4(2), Tower-A, 1St, 3Rd, 4Th, 5Th & New Delhi. Tower-B, Ground, 2Nd 5Th Floor, S.P. Infocity, Udyog Vihar, Dundahera, Gurgaon, Haryana, 122016 Pan-Aabcc5056G Appellant Respondent Appellant By Shri K.M.Gupta & Ms. Shruti Kimta, Ar Respondent By Shri S.K.Jadhav, Cit Dr Date Of Hearing 22.07.2025 Date Of Pronouncement 25.07.2025 Order

Section 115Section 115OSection 250Section 9

declaring total income at INR 1,52,79,96,910/- in the return of income filed on 29.11.2014. Since the assessee has entered into international transactions therefore, the matter was referred to TPO for determination of the Arm’s Length Price (“ALP”) of such transactions. The TPO vide order dated

Ledvance Private Limted, Gurgaon vs. DCIT, Circle-2(1), Delhi

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

ITA 540/DEL/2022[2017-18]Status: DisposedITAT Delhi25 Jul 2025AY 2017-18

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

Section 234Section 50BSection 92(3)Section 92C(1)

returned income declared by the Appellant. 2. The Ld. AO/DRP/TPO erred in ignoring the fact that the transaction under consideration is not an international transaction and in doing so have grossly erred in: 2.1. Ignoring that the transaction under consideration is between two domestic entities and hence any adjustment being ... this appeal.” 3. The solitary issue involved in this case is to whether the transaction between two domestic entities would be construed as international transaction and attracts TP provisions. It is the contention of the assessee that the assessee has transferred its business as a going concern(Slump sale

Dell International Services India Private Limited, Bangalore, Karnataka vs. Deputy Commissioner of Income-Tax, Circle - 2(1)(1), Bangalore, Karnataka

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

ITA 1488/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Jul 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kit(Tp)A No.1488/Bang/2024 Assessment Year : 2014-15

For Appellant: Ms. Tanmaye Rajkumar, ARFor Respondent: Dr. Divya K. J, CIT(DR)(ITAT), Bangalore
Section 144C(13)Section 92C

assessee. Subsequently, the case was referred to the TPO after obtaining necessary approvals. As per Form 3CEB and TP study report, following are the international transactions and financial statements: IT(TP)A No.1488/Bang/2024 Page 3 of 14 4. Further, financials of the tax payer as reconciled ... under: 5. The tax payer has reported international transaction in respect of provision of marketing support services and technical support services. The ALP of the international transactions for the services provided to the AEs has been determined by applying Transaction Net Margin Method (TNMM) stating IT(TP)A No.1488/Bang/2024 Page