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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

Biogenex Life Sciences Private Limited, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

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

ITA 68/HYD/2022[2017-18]Status: DisposedITAT Hyderabad07 May 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR
Section 143(3)Section 92C

with relevant operations of the tested party. 5.8 ought to have adjusted the operating margin of the assessee by considering the differences between the international transactions undertaken with AE and comparable uncontrolled transactions. 6. The Ld. AO/TPO/DRP erred in selecting incorrect comparables by applying the fresh search process by rejecting ... holding company, filed its return of income for A.Y. 2017-18 on 30.11.2017 declaring total loss of Rs.28,74,492/-. 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

Tata Consumer Products Limited, Kolkata vs. D.C.I.T., Circle-4(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 426/KOL/2022[2018-2019]Status: DisposedITAT Kolkata07 May 2025AY 2018-2019

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Ram Sehadri, CAFor Respondent: Shri Praveen Kishore, CIT, DR
Section 144C(13)Section 144C(5)Section 153Section 153B

passing a Final Assessment Order. Section 144C is entitled 'Reference to dispute resolution panel' and sets out the procedure for assessment in cases involving international transactions. The procedure contemplated commences with a Draft Assessment Order (DAO) being passed by the Assessing Officer. The Assessee could either accept the same

Tata Consumer Products Limited (Erstwhile Tata Global Beverages Limited), Kolkata vs. D.C.I.T., Circle-4(1), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 385/KOL/2022[2017-2018]Status: DisposedITAT Kolkata07 May 2025AY 2017-2018

Bench: Shri George Mathan & Shri Sanjay Awasthi

For Appellant: Shri Ram Sehadri, CAFor Respondent: Shri Praveen Kishore, CIT, DR
Section 144C(13)Section 144C(5)Section 153Section 153B

passing a Final Assessment Order. Section 144C is entitled 'Reference to dispute resolution panel' and sets out the procedure for assessment in cases involving international transactions. The procedure contemplated commences with a Draft Assessment Order (DAO) being passed by the Assessing Officer. The Assessee could either accept the same

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 267/CHNY/2025[2016]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

order of the Ld.AO for the reasons mentioned therein. 11.0 The Ld. Counsel for the assessee submitted that the assessee has entered into international transaction for availing marketing and Consultancy Services with its AEs. Based upon the recommendations of the Ld. TPO vide his order dated 31.10.2017 u/s 92CA ... IDBI Bank, the same needs to be adopted. In the facts and circumstances of the case, it is held that the ALP of the international transaction for issuance of corporate guarantee is to be adopted as 1%. The Page - 8 - of 15 ITA No.265, 266 &267 /Chny/2025 AO/TPO is directed

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 266/CHNY/2025[2015]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

order of the Ld.AO for the reasons mentioned therein. 11.0 The Ld. Counsel for the assessee submitted that the assessee has entered into international transaction for availing marketing and Consultancy Services with its AEs. Based upon the recommendations of the Ld. TPO vide his order dated 31.10.2017 u/s 92CA ... IDBI Bank, the same needs to be adopted. In the facts and circumstances of the case, it is held that the ALP of the international transaction for issuance of corporate guarantee is to be adopted as 1%. The Page - 8 - of 15 ITA No.265, 266 &267 /Chny/2025 AO/TPO is directed

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 265/CHNY/2025[2014]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

order of the Ld.AO for the reasons mentioned therein. 11.0 The Ld. Counsel for the assessee submitted that the assessee has entered into international transaction for availing marketing and Consultancy Services with its AEs. Based upon the recommendations of the Ld. TPO vide his order dated 31.10.2017 u/s 92CA ... IDBI Bank, the same needs to be adopted. In the facts and circumstances of the case, it is held that the ALP of the international transaction for issuance of corporate guarantee is to be adopted as 1%. The Page - 8 - of 15 ITA No.265, 266 &267 /Chny/2025 AO/TPO is directed

Mane India Private Limited, Hyderabad vs. ACIT., Circle-5(1), Hyderabad

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

ITA 686/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad06 May 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.686/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) M/S Mane India (P) Ltd Vs. Acit Hyderabad Circle 5(1) Pan:Aaccm1243J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Mahima Goud राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 11/02/2025 घोषणा की तारीख/Pronouncement: 06/05/2025 आदेश/Order

For Appellant: Advocate Mahima GoudFor Respondent: : Smt. M. Narmada, CIT(DR)
Section 143(3)Section 144C(5)

Mane India P Ltd 3. The solitary issue arises in the appeal of the assessee is regarding the TP adjustment made on account of international transactions of payment made to the AE of the assessee towards management and technical assistance services. The assessee is in the business of research, production ... processing and distribution of flavours and fragrance products. The assessee has reported international transactions which are reproduced by the TPO in Para 3 of the order as under: Page 4 of 12 ITA No 686 of 2024 Mane India P Ltd Page

Nippon Yusen Kabushiki Kaisha, Kolkata vs. CIT-(It &Tp), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1268/KOL/2019[2014-15]Status: DisposedITAT Kolkata06 May 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Nippon Yusen Kabushiki Kaisha Cit-(It &Tp) C/O Yusen Logistics (India) 1St Floor, Aayakar Bhawan Private Limited, Central Plaza, Poorva, 110, Shanti Pally, Vs. Room No.202, 2Nd Floor, 2/6, Kolkata - 700107, Kolkata, Sarat Bose Road, Kolkata, West Bengal, 700107 West Bengal, 700020 (Appellant) (Respondent) Pan No. Aabcn1372N Assessee By : Shri Ketan Ved, Ar Revenue By : Shri Pradip Kumar Mondal, Dr Date Of Hearing: 19.03.2025 Date Of Pronouncement : 06.05.2025

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri Pradip Kumar Mondal, DR
Section 143Section 143(3)Section 144Section 144C(3)(a)Section 153(1)Section 263Section 92C

order that the ld. AO had not referred the issue to the Transfer Pricing Officer (TPO) for determining the Arms Length Price about the international transactions. The ld. Pr.CIT stated in the order that though the ld. AO had issued the letter to the assessee as to why the matter ... should not be referred to ld. Transfer Pricing Officer for benchmarking the international transactions which was also replied by the ld. Assessing Officer. AO however thereafter had not mentioned as to why the issue was not referred to the ld. Transfer Pricing Officer. Accordingly, the assessee was issued show cause

DCIT-2(1)(1), Mumbai vs. Iss Facility Services India Pvt. Ltd., Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1980/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 May 2025AY 2015-16

Bench: Shri Pawan Singh, Hon’Bleshri Girish Agrawal, Hon’Blec.O. No.97/Mum/2025 (By Assessee) (Physical Hearing) Dy Commissioner Of Income Tax, Iss Facility Services India Pvt Ltd, Ground Floor, East Wing, Circle -2(1)(1), Room No. 575, Leela Business Park, 5Th Floor, Aayakar Bhawan, Vs Near Airport Road, Metro Station, M.K. Road, Mumbai-400020, Andheri East, Mumbai. Pan. Aabci 3815 M Appellant (Respondent) Revenue Represented By : Shri S.S. Bhagat Sr Dr Assessee Represented By : Shri Nikhil Tiwari, Ca Date Of Hearing : 06.05.2025 Date Of Pronouncement Of Order : 06.05.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh;

Section 143(3)Section 153Section 254(1)Section 92C(1)

case of the assessee as referred above. The relevant extract of the decision is reproduced as under: “3.9 As regards the international transaction of Payment of Global Client Management Fee, it is also evident that TPO in subsequent assessment years has partially accepted the assessee's submission of rendition ... that provisions of Section 92C(1)of the Act mandates adoption of one of the prescribed method mentioned therein for determining the ALP of international transactions. It is not in dispute that the disallowances/adjustments made by the ld. TPO to ALP were made without following any of the prescribed methods

Dsm Shared Services India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

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

ITA 501/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 43B

filed its Return of Income (“ROI”) for A.Y. 2018-19 declaring total income at Rs.4,89,46,490/- on 30.11.2018. In view of the international transactions involved during the year under consideration, for determination of Arm’s Length Price (“ALP”), the case was ITA No.501/Hyd/2022 6 referred to Learned Transfer ... Rules, 1962, the net profit margin arising in comparable uncontrolled transactions should be adjusted to take into account the differences, if any, between the international transaction and comparable uncontrolled transactions which could materially affect the amount of net profit margin. In our view, difference in levels of working capital between

Gainsight Software Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad

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

ITA 200/HYD/2021[2016-17]Status: DisposedITAT Hyderabad05 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 271ASection 37(1)Section 438

Learned Assessing Officer (Ld. AO’) / Learned ‘lransfer P ng Officer (Ld. TPO’) in making an adjustment of Rs. 2,71,60,259 to the international transaction pertaining to provision of software development services. 2, On the facts and in the cireumstances of the ease ... case and in law, the learned AO/TPO erred in not adopting the upper turnover filter while doing the comparability analysis for the Appellant's international transaction pertaining to provision of Software Development Segment (‘SWI’) scgment. 13. On the facts and in the circumstances of the case

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

undertaking a fresh economic analysis during the course assessment proceedings and thereby making an adjustment of Rs. 16,21,20,521 towards the international transactions with AEs. 2. Rejection of use of multiple year data : Rejecting the use of multiple and using data for the FY 2013-14 only ... 31st 2014 relating to provision of software services to AEs : a) Not appreciating that the instant transaction is not covered in the definition of international transaction as defined u/s 92B of the Act in the facts and circumstances of the case. b) Not appreciating the facts and circumstances surrounding

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

In the result, the appeal of the assessee bearing ITA No

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

under section 92CA of the Act, after obtaining due approval from the competent authority, for determining the arm’s length price in respect of international transactions undertaken by the assessee. Pursuant to the reference, the TPO proposed an adjustment of Rs.11,26,24,233/- to the TP study reported

Atotech India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

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

ITA 6571/DEL/2016[2012-13]Status: HeardITAT Delhi02 May 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri Manish Agarwalatotech India Private Dy. Cit, Limited, Circle-1(1), 66 Km Stone, Nh-8, Delhi Vs. Gurgaon. Jaipur Highway, Gurgaon. (Appellant) (Respondent)

made by TPO initially) and in doing so have grossly erred in. 4.1 treating the outstanding receivables from AEs as a separate international transaction. 4.2 re-characterising the overdue amount on receivables from AEs as an unsecured interest-free loan. 4.3 Without prejudice, the Ld. AO/TPO erred on facts ... characterized the delay in receipt of receivables as interest free unsecured loans advanced to the AE and treated the receivables from AE as international transaction in the nature of capital funding. Accordingly, the TPO has used CUP being SBI based rate plus 300 basis points, and applied interest rate

Venetian Ldf Projects LLP, Gurgaon vs. ACIT Circle-4(1), Gurgaon

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2019[2014-15]Status: DisposedITAT Delhi01 May 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

ITA No. 3533/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT

Icici Bank Ltd, Mumbai vs. Addl CIT RG 3 (1), Mumbai

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

assessee appeared before the ld. AO and filed requisite details as called for. 2. 1. The Ld. AO noted that the assessee had international transactions with its associated enterprise's. Accordingly, reference was made to the Ld.TPO to compute the ALP of the transaction. 2. 2. Upon receipt ... reference u/s 92CA(1) of the Act, the Ld.TPO called upon the assessee to furnish details in respect of international transactions undertaken by the assessee in Form 6 3CEB. Upon furnishing the relevant details, the Ld.TPO observed that, following were the international transactions undertaken by the assessee: ITA No.4249 & 4159/Mum/2014

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

assessee appeared before the ld. AO and filed requisite details as called for. 2. 1. The Ld. AO noted that the assessee had international transactions with its associated enterprise's. Accordingly, reference was made to the Ld.TPO to compute the ALP of the transaction. 2. 2. Upon receipt ... reference u/s 92CA(1) of the Act, the Ld.TPO called upon the assessee to furnish details in respect of international transactions undertaken by the assessee in Form 3CEB. Upon furnishing the relevant details, the Ld.TPO observed that, following were the international transactions undertaken by the assessee: Transactions Methodolo Amount

Deputy Commissioner of Income Tax, Circle 8 Pune, Pune vs. Alfa Laval India Pvt Ltd, Pune

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

ITA 1723/PUN/2024[2017-18]Status: DisposedITAT Pune29 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1723/Pun/2024 Assessment Year : 2017-18

For Appellant: Shri H. AnandaFor Respondent: Shri Nikhil Pathak
Section 143Section 143(2)Section 143(3)Section 92C

reference made by the Assessing Officer to the Transfer Pricing Officer for computation of Arm's Length Price (ALP) in relation to the international transaction with its Associate Enterprises, the Transfer pricing Officer (TPO) vide order dated 28.01.2021 passed u/s.92CA(3) made an adjustment of Rs.1 ... international transaction relating to the export of traded spares to the AE. Thereafter, NFAC Delhi passed the Assessment Order u/s.143 r.w.s.144C(3) of the Act on 24.06.2021 making additions/disallowances assessed the income at Rs.2,29,81,09,549/-. Details of additions are given below : Sr. Particulars Amount

The Deputy Commissioner of Income Tax Circle 3(2), Gangtok, Gangtok Sikkim vs. Sikkim State Cooperative Supply and Marketing Federation Limited, Gangtok Sikkim

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

ITA 1711/KOL/2024[2020-21]Status: DisposedITAT Kolkata29 Apr 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 274Section 40Section 80GSection 80PSection 80P(2)(d)

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

ACIT, Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

ITA 3705/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Apr 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 10ASection 115JSection 144BSection 144CSection 147Section 801B(9)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA