“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

Jungheinrich Lift Truck India Private Limited, Mumbai vs. Assessment Unit, National E Assessment Centre- Delhi, Delhi

In the result, the appeal is accordingly allowed for statistical purposes

ITA 4260/MUM/2024[2020-2021]Status: DisposedITAT Mumbai21 May 2025AY 2020-2021

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanvs. Assessment Jungheinrich Lift Truck Unit/Nfac/Dcit India Private Limited Circle 15(1)(2), 4Th Floor, Delphi A Wing, Mumbai Central Avenue, Aayakar Bhavan, Hiranandani, Business Mumbai. Park, Powai, Mumbai, Maharashtra-400 076 Pan/Gir No. Aaccj7808G (Applicant) (Respondent) Assessee By Shri Ajit Jain / Shri Siddesh Chaugule / Shri Rishab Parekh, Ld. Ars Revenue By Shri Kiran Unavekar, Sr. Dr Date Of Hearing 05.03.2025 Date Of Pronouncement 21.05.2025 आदेश / Order Per Raj Kumar Chauhan, Jm: This Appeal Is Directed Against The Assessment Order Dated 26.06.2024 Passed By Assessment Unit (Hereinafter Referred As Ld. Ao) For Ay 2020-21 In Pursuance To The Direction Of Ld. Drp-1, Mumbai Dated 14.06.2024

Section 143(3)Section 144C(13)Section 43A

India Private Limited 2.1 The learned Transfer Pricing Officer ("TPO")/ AU/ DRP has erred in computing the Arm's Length Price ("ALP") of the international transaction of "Reimbursement of expenses" with transaction value of INR 75,08,637 at NIL without appreciating the fact that such expenses are third party ... activities for lift trucks, etc. During the scrutiny 7 Jungheinrich Lift Truck India Private Limited assessment, it is noticed that assessee has entered into international transaction of import of trucks and export of trucks alongwith composite payments as well as reimbursement of expenditure and a reference was made for determination

North Delhi Metro Mall Private Limited, Delhi vs. Deputy Commissioner of Income Tax Circle 16(1), C.R. Building, Delhi

ITA 5192/DEL/2024[2021-22]Status: DisposedITAT Delhi21 May 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2021-22 North Delhi Metro Mall Private Vs Dcit, Limited, Circle-16(1), The Mall Road, Delhi. Khyber Pass Civil Lines, Delhi – 110 054, Pan: Aadcm7638N

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri Jitender Chand, Sr. DR

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

overall supervision and co-ordination, in respect of development of such projects. During the year under consideration, NDMM had entered into the following international transaction with its AE which has suffered a TP adjustment. Nature of transaction Amount in INR Outcome of TP Order Receipt of Supervision ... dated October 30, 2023 was passed proposing an adjustment of INR 9,83,37,432 to the arm’s length price of the international transactions undertaken by the Appellant with its AE. The Ld. AO passed the draft assessment order under Section 144C(1) of the Act (‘Draft Order’) dated

Humboldt Wedag India Private Ltd, New Delhi vs. DCIT Circle - 10(1), New Delhi

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

ITA 4726/DEL/2024[2021-22]Status: DisposedITAT Delhi21 May 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumarhumboldt Wedag India Private Ltd., Vs. Addl./Joint/Deputy/Asstt. A – 36, Mehtab House, Commission Of Income-Tax, Mohan Co-Op. Estate, Mathura Road, National E-Assessment Centre, New Delhi – 110 044. Circle 10(1), Delhi. (Pan : Aaach7474G) (Appellant) (Respondent) Assessee By : Shri Rajineesh Verma, Ca Ms. Hem Lata Verma, Ca Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 09.04.2025 Date Of Order : 21.05.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 05.09.2024 Passed U/S 143(3) R.W.S.144C (13) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) Subsequent To The Directions Of The Ld. Dispute Resolution Panel (Drp)/Tpo Vide Order Dated 07.08.2024 For Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “Pertaining To Transfer Pricing Matters: Adjustment Rs.10,486,841 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Dispute Resolution Panel ('Ld. Drp'), The Learned Transfer Pricing

For Appellant: Shri Rajineesh Verma, CAFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(3)Section 144CSection 144C(8)Section 153Section 234ASection 270ASection 92CSection 92C(2)

benefit of (+/-) 3% as provided in the proviso to Section 92C(2) of the Act, while determining the arm's length price of the international transactions of the Appellant. 6 On without prejudice to the above grounds, on the facts and in the circumstances of the case

Excelra Knowledge Solutions Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1319/HYD/2024[2021-22]Status: DisposedITAT Hyderabad20 May 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Abhishek BoobFor Respondent: MS. M. Narmada, CIT-DR

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

support services expenses amounting to Rs.10,17,19,353/-towards payment to it’s AEs’ and reported the said payment in Form-3CEB as "International Transaction'. The appellant company has conducted a transfer pricing study report for the impugned assessment year in respect of international transactions involving payment of business ... u/sec.92CA of the Income Tax Act, 1961 was made to the TPO to determine the Arms Length Price [in short “ALP”] in respect of international transactions reported by the appellant company. During the course of TP proceedings, the TPO called-upon the assessee to file relevant evidences including agreements with

Aquity Solutions India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 15(1)(1), Mumbai

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

ITA 4817/MUM/2024[2020-21]Status: DisposedITAT Mumbai20 May 2025AY 2020-21

Bench: Shri Sandeep Singh Karhailshri Girish Agrawal

For Appellant: Shri Harsh ShahFor Respondent: Shri Ajay Ojha, Sr.DR

Section 143(3)Section 144C(13)Section 144C(5)Section 234ASection 234B

Rs.5,70,15,937/- to the total income of the Appellant on account of interest chargeable on trade receivables in relation to the international transactions entered into by the Assessee with its Associated Enterprise ('AE'). 2. On the facts and circumstances of the case and in law, the learned ... learned TPO, under the directions of the Hon'ble DRP, erred in treating trade receivables as a separate international transaction undertaken by the Assessee without any material in support thereof. 3. On the facts and circumstances of the case and in law, the learned AO/ learned TPO, under the directions

Mr. Tasavver Husain, Farrukhabad vs. ACIT, Farrukhabad

In the result, appeal filed by the assessee is allowed

ITA 96/AGR/2023[2017-18]Status: DisposedITAT Agra19 May 2025AY 2017-18

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

Section 270A

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

Mr. Tasavver Husain, Farrukhabad vs. ACIT, Farrukhabad

In the result, appeal filed by the assessee is allowed

ITA 95/AGR/2023[2017-18]Status: DisposedITAT Agra19 May 2025AY 2017-18

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singh

Section 270A

Plant Lipids (P) Ltd., Kadayiruppu vs. DCIT, Corporate Circle-2(1), Kochi

In the result appeal filed by assessee stands allowed

ITA 598/COCH/2024[2020-21]Status: DisposedITAT Cochin19 May 2025AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

For Appellant: Shri Thomson Thomas, A.RFor Respondent: Shri Sanjit Kumar Das, D.R

Section 143(3)Section 144(1)Section 144CSection 80GSection 92C

Assessment Year 2020-21, it filed the return of income on 27.01.2021 declaring a total income of Rs.160,94,63,940/-. In respect of International Transactions entered into by the assessee company, the Assessing officer made a reference to the Transfer Pricing Officer (TPO) u/s 92CA (l) of the Actfor ... determining the arm's length price in respect of the International Transactions. By order passed u/s 92CA(3) of the Act, the Transfer Pricing Order made an adjustment of Rs.2,03,38,752/- towards notional guarantee commission in respect of corporate guarantee given by the assessee for its Subsidiary.After receiving

Sequence Design (India) Private Limited, Pune Maharashtra vs. Joint Commissioner of Income Tax Circle 1(1) Pune, Pune

In the result, appeal of the assessee is allowed

ITA 2106/PUN/2024[2015-2016]Status: DisposedITAT Pune16 May 2025AY 2015-2016

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2106/Pun/2024 Assessment Year : 2015-16

For Appellant: Shri Nikhil PathakFor Respondent: Shri Manish Mehta

Section 143(1)(a)Section 143(3)Section 250Section 271ASection 273BSection 92D(1)

repatriated by the Associated Enterprises in the year under appeal towards transfer pricing adjustments on the value of international transactions undertaken during the earlier years and therefore the penalty was not leviable during the current year. 2.2 The learned CIT(A) erred in ignoring the fact that the Appellant received ... required to be reported in Form 3CEB, the learned AO erred in levying penalty under 271AA of the Act on the entire value of international transactions of Rs 13,29,97,947/- already reported in Form 3CEB by the Appellant for AY 2015-16, which is equivalent

DCIT., Central Circle-3(2), Hyderabad vs. Jodas Expoim Private Limited, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 702/HYD/2024[2016-17]Status: DisposedITAT Hyderabad16 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.702/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Dy. C.I.T Vs. M/S. Jodas Expoim (P) Ltd Central Circle 3(2) Siddipet, Telangana Hyderabad Pan:Aabcj8653L (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bharadwaj, Ca राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 05/03/2025 घोषणा की तारीख/Pronouncement: 16/05/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Revenue Is Directed Against The Order Dated 7/5/2024 Arising From The Penalty Order Passed U/S 271Aa Of The I.T. Act, 1961 For The A.Y 2016-17. 2. The Revenue Has Raised The Following Grounds Of Appeal: “1) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Deleting The Penalty Levied U/S 271Aa Of The Act Even Though The Assessee Failed To File Form 3Ceb As Mandated U/S 92E Of The Act Within The Time Prescribed U/S 139(1) Of The Act? 2) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Deleting The Penalty Levied U/S 271Aa Of The Act Even Though The Assessee Failed To Report

For Appellant: Shri Ravi Bharadwaj, CAFor Respondent: : Shri Srinath Sadanala, DR

Section 115JSection 133ASection 139(1)Section 233ASection 271ASection 92ASection 92CSection 92DSection 92E

271AA of the Act even though the assessee failed to report Page 1 of 6 ITA No 702 of 2024 JODAS EXPOIM P LTD internation transactions for the A.Y; 2016-17 which assessee failed to report international transactions for the A.Y. 2016- 17 which came to light during the course ... reason that the assessee maintained proper TP documentation whereas the penalty is levied on account of the assessee’s failure to report international transactions by filing Form 3CEB within the prescribed time? 4) Any other ground that may be urged at the time of hearing.” 3. The assessee company filed

Vertex Offshore Services Private Limited, Hyderabad vs. Dict, Circle-8(1), Hyderabad

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

ITA 204/HYD/2021[ 2016-17]Status: DisposedITAT Hyderabad16 May 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: MS. M. Narmada, CIT-DR

Section 143(3)Section 144C(1)Section 144C(5)Section 92CSection 92C(3)

Vertex US. The company operates on cost plus margin model. During the financial year relevant to assessment year under consideration, the appellant has reported international transactions with it’s Associated Enterprises [in short “AE”] in respect of provision of ITES services of Rs.24,10,97,420/-. The appellant has conducted ... through CASS and during the course of assessment proceedings, a reference u/sec.92CA has been made to the TPO for determination of the ALP of international transactions of the appellant company. The TPO has examined the TP documentation submitted by the appellant company and after considering the relevant filters applied

M/S Essar Shipping Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 5(1)(1), Mumbai

In the result, ground no. 5 raised by the assessee is dismissed

ITA 4440/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 May 2025AY 2020-21

Bench: Ms. Kavitha Rajagopal, Jm & Shri Omkareshwar Chidara, Am

For Respondent: Shri. Piyush Chaturvedi

Section 143(2)Section 144Section 144C(1)Section 41Section 92B(2)Section 92C

Notices u/s.143(2) of the Act dated 29.06.2021 was issued and served upon the assessee. The ld. AO observed that the assessee has reported international transaction u/s.92B(2) of the Act in form 3CEB for which the ld. AO made a reference to the Transfer Pricing Officer (‘TPO' in short ... u/s.92CA(1) of the Act. The ld. TPO vide order dated 14.06.2023 proposed adjustments on the Arm's Length Price of the international transaction towards interest of lease loan payment for ships taken on Bare Boat Charter cum Demise amounting to Rs.51,46,215/- and guarantee commission of Rs.3

Bando India Pvt. Ltd., Gurgaon vs. ITO, Ward- 1(3), Gurgaon

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

ITA 606/DEL/2018[2013-14]Status: DisposedITAT Delhi16 May 2025AY 2013-14

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

Section 143(2)Section 143(3)Section 147

income filed by the assessee was selected for scrutiny and statutory notices u/s 143(2) and 142(1) were issued to the assessee. Since, international transactions were (in short ‘TPO’) on 04.02.2016. The TPO after making certain adjustments, passed the order. Thereafter, the assessee filed its objection before the learned

DCIT, Gurgaon vs. M/S. Motorola India Pvt. Ltd., Gurgaon

In the result, the appeal being ITA No

ITA 3646/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(3)Section 37(1)Section 43B

transfer pricing study (TP Study) and the fresh search conducted by the appellant in determining the arm's length price with respect to the international transactions undertaken by the appellant to provide software development services, to its overseas group companies. 5.4 That the Ld. CIT (Appeals) erred in supporting ... erred in upholding the adjustment to the income of the appellant of Rs.27,52,24,842 by holding that the appellant's international transaction of provision of software development services to the Associated Enterprises ('AEs') does not satisfy the arm's length principle as envisaged under

Motorola Solutions India Pvt. Ltd., Gurgaon vs. ACIT, Gurgaon

In the result, the appeal being ITA No

ITA 3641/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(3)Section 37(1)Section 43B

M/S. Motorola Solutions India Private Limited, Gurgaon vs. ACIT, Gurgaon

In the result, the appeal being ITA No

ITA 4789/DEL/2014[2005-06]Status: DisposedITAT Delhi16 May 2025AY 2005-06

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(3)Section 37(1)Section 43B

Vishal Kishorilal Jain, Nagpur vs. DCIT/ACIT Circle-4, Nagpur

In the result, assessee’s appeal for A

ITA 108/NAG/2025[2016-17]Status: DisposedITAT Nagpur15 May 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Abhay Y. Marathe

Section 132Section 139(1)Section 143(1)Section 147Section 148Section 2(40)Section 68Section 69

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

Delicatessen Engineering Services Private Limited, Hyderabad vs. DCIT., Circle- 8(1), Hyderabad

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

ITA 835/HYD/2024[2020-21]Status: DisposedITAT Hyderabad15 May 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.835/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Delicatessen Vs. Dy. Cit. Engineering Services Circle- 8(1), Private Hyderabad Limited,Hyderabad Pan:Aagcd8678N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 26/02/2025 घोषणा की तारीख/Pronouncement: 16/05/2025 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The I.T. Act, 1961 Dated,18/07/2024, In Pursuant To The Directions Issued By The Drp-1 Bengaluru, Dated 26/02/2024 U/S 144C(5) Of The I.T. Act, 1961 & Relating To A.Y.2020-21. Page 1 Of 32

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri B Bala Krishna, CIT(DR)

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

company brought Global Engineering Services (GES) Division of MW High Tech Project India (P) Ltd through business transfer agreement. The appellant has reported international transaction in respect of sale engineering design services to its AEs. The ALP of the international transaction in EDS segment provided to its AEs has been ... course of assessement proceedings, a reference u/s 92CA of the I.T. Act, 1961 has been made to the TPO to determine the ALP of international transactions with its AEs. During the course of TP proceedings, the TPO examined the taxpayers TP study and relevant search criteria adopted for selection

Deputy Commissioner of Income Tax, Circle-5(1), Kolkata vs. Dhunseri Ventures Limited, Kolkata

In the result, the appeal filed by the revenue is dismissed

ITA 968/KOL/2024[2016-17]Status: DisposedITAT Kolkata15 May 2025AY 2016-17

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 80ISection 92C

115JB after making certain addition and disallowances. The case of the assessee was referred to Transfer Pricing scrutiny in respect of international transaction and specified domestic transaction. The TPO in the order u/s 92CA proposed downward adjustment of Rs. 12,69,60,600/- in respect of deduction claimed u/s 80IA

Rungta Irrigation Limited, Delhi vs. A.C.I.T., Central Circle 3(1), Kolkata

ITA 2315/KOL/2024[2013-14]Status: DisposedITAT Kolkata15 May 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

please State: (a)The income originally assessed 1,75,03,350/- (b) Whether assessee has failed to furnish a report in respect of any international transaction which he was required u/s 92E. (c) Whether it is a case of under assessment, assessment at too low rate, assessment which has, been