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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

DCIT (It) 2(2)(2), Mumbai vs. The Hongkong and Shanghai Banking Corp Ltd, Mumbai

In the result, the captioned appeals by the assessee are partly

ITA 4787/MUM/2016[2006-07]Status: DisposedITAT Mumbai28 Jun 2024AY 2006-07

Bench: Shri Narendra Kumar Billaiya, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm's length by the Id. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently

The Hong Kong & Shanghai Banking Corporation Ltd., Mumbai vs. Addl. Director of Income Tax (International Taxation) - Range -3, Mumbai

In the result, the captioned appeals by the assessee are partly

ITA 4767/MUM/2016[2007-08]Status: DisposedITAT Mumbai28 Jun 2024AY 2007-08

Bench: Shri Narendra Kumar Billaiya, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm's length by the Id. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently

The Hong Kong & Shanghai Banking Corporation Ltd., Mumbai vs. Addl. Director of Income Tax (International Taxation) - Range -3, Mumbai

In the result, the captioned appeals by the assessee are partly

ITA 4766/MUM/2016[2006-07]Status: DisposedITAT Mumbai28 Jun 2024AY 2006-07

Bench: Shri Narendra Kumar Billaiya, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm's length by the Id. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently

Addi CIT Spl. Range- 6, New Delhi vs. Maharashtra Seamless Ltd., New Delhi

In the result, LIBOR + 300 points be charged and corporate guaranteed commission be charged @ 0

ITA 7700/DEL/2019[2013-14]Status: DisposedITAT Delhi27 Jun 2024AY 2013-14

Bench: Dr. B. R. R. Kumar, Sh. Vimal Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. Prakshit Singh, Sr. DR

basis points which is 3.23% p.a. approx and the same was declared in the return of income filed by the assessee. 4. The above International transaction of interest received of Rs. 19,88,755/-was benchmarked by the assessee adopting CUP method, being the appropriate method. The assessee has considered ... held to be prospective and not retrospective. Hence, the contention of the appellant that the transaction pertaining to corporate guarantee was not an international transaction within the definition of the transfer pricing regulations in India is not correct. Moreover, the corporate guarantee has been charged by the appellant itself during

Ge Subsidiary Inc, 63 (Successor in Interest of Monogram Licesing International Inc.), Mumbai vs. ACIT (It) RG. 3 (2)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5906/MUM/2018[2014-15]Status: DisposedITAT Mumbai26 Jun 2024AY 2014-15

Bench: Shri Amit Shukla & Shri Gagan Goyalge Subsidiary Inc, 63 (Successor In Interest Of Monogram Licensing International Inc.) C/O. Pwc House, Plot No. 18 A, Guru Nanak Station Road, Bandra, Mumbai- 400050 Pan: Aadcm6233F Appellant Vs. Acit (Intl Taxation) - 3(2) (2), Mumbai, Room No. 1615, Air India Building, Nariman Point, Mumbai- 400 021 Respondent

For Appellant: Shri Dhanesh Bafna, Shri PratikFor Respondent: Shri Abhishek Tharwal, Ld. DR
Section 143(3)Section 144C(13)Section 234BSection 92C(3)

further making an enhancement of Rs. 1, 15, 97,802/- to the total income of the Appellant on account of value of the international transaction of receipt of royalty by the Appellant. 2. on the facts and circumstances of the case and in law, the learned DRP/learned AO erred ... Central Board of Direct Taxes are satisfied. 2.3. Not appreciating that Chapter X provisions are not applicable in the Appellant's case as the international transactions of receipt of royalty do not result in tax avoidance by way of shifting of any profits from India. 2.4. in making transfer pricing

Astrazeneca Pharma India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 284/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Jun 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Sri Nikhil Tiwari, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 37Section 37(1)

analysis undertaken by the Appellant in accordance with the provisions of the Act read with the Rules and thereby holding that the Appellant's international transactions relating to manufacturing segment from Associated Enterprises (“AE’s”) is not at arm's length; Adjustment of INR 6,19,06,837 pertaining ... computing incorrect operating margin of the Appellant. 15. without prejudice to above, erred in not restricting the transfer pricing adjustment to the value of international transaction; 16. without prejudice to above, erred in not making suitable adjustments to account for differences in the risk profile of the Assessee

Tata International Ltd, Mumbai vs. Addl CIT 7(3), Mumbai

ITA 2232/MUM/2014[2009-10]Status: DisposedITAT Mumbai24 Jun 2024AY 2009-10

Bench: Shri Amit Shukla & Shri Gagan Goyal

For Appellant: Shri Nitesh Joshi a/w Ninad PatadeFor Respondent: Ms. Dhivya Ruth J., Ld. DR
Section 14Section 144CSection 36(1)Section 36(1)(iii)Section 37(1)Section 57

respect of the Appellant's non-recovery of any fees or commission from its concerned AEs, the issuance of LOCs, is not an international transaction and does not trigger applicability of Section 92 of the Income Tax Act, 1961 2.8 Without prejudice to the foregoing ground, and assuming whilst denying ... house engaged in exporting variety of products including automobile spare parts, steel, engineering items, chemicals and leather products, etc. The assessee has entered into international transactions as per Form No. 3CEB, hence a reference u/s. 92CA(1) of the Act was made to the Transfer Pricing Officer (TPO) to compute

Dy. Commissioner of Income Tax (I.T.)- 3(2)(1), Mumbai vs. Mckinsey and Sompany Singapore Pte. Ltd., Singapore

In the result, appeals of the assessee are allowed

ITA 2535/MUM/2023[2013-14]Status: DisposedITAT Mumbai21 Jun 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: S/Shri Porus F.Kaka & Divesh ChawlaFor Respondent: Shri Anil Sant, Addl.CIT-DR

Briefly stated the facts of the case are that the assessee is a foreign company, incorporated in Singapore. The assessee has entered into international transactions with its Associated Enterprises (AEs), McKinsey & Co., Inc. (Indian Branch) during the financial year under consideration. Transfer Pricing Study report in Form 3CEB was filed

DCIT 3(4), Mumbai vs. Tata Consultancy Services Ltd., Mumbai

Accordingly. This ground is allowed for statistical purposes

ITA 2477/MUM/2021[2015-16]Status: DisposedITAT Mumbai21 Jun 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: S/Shri Porus F.Kaka & Manish KanthFor Respondent: Ms.Dhivya Ruth J, Sr.DR
Section 143(3)

which act as marketing and sales support companies of TCS. 5. During the year under consideration, the assessee has reported among others the following international transactions with its AEs:- Sr. Nature of transaction Transaction Method No. amount (₹) 1. Provision of software and 45359,63,87,176 TNMM consultancy services ... mind to the decisions relied upon. Insofar as the contention of learned Sr. Counsel for the assessee that provision of guarantee is not an international transaction as per section 92B of the Act, we are unable to accept such contention. In our considered opinion, after introduction of Tata Consultancy Services

Tata Consultance Services Ltd, Mumbai vs. DCIT Ltu-1, Mumbai

In the result, the appeal filed by the Revenue and the assessee are dismissed

ITA 2413/MUM/2021[2015-16]Status: DisposedITAT Mumbai21 Jun 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: S/Shri Porus F.Kaka & Manish KanthFor Respondent: Ms.Dhivya Ruth J, Sr.DR
Section 143(3)

which act as marketing and sales support companies of TCS. 5. During the year under consideration, the assessee has reported among others the following international transactions with its AEs:- Sr. Nature of transaction Transaction Method No. amount (₹) 1. Provision of software and 45359,63,87,176 TNMM consultancy services ... mind to the decisions relied upon. Insofar as the contention of learned Sr. Counsel for the assessee that provision of guarantee is not an international transaction as per section 92B of the Act, we are unable to accept such contention. In our considered opinion, after introduction of Tata Consultancy Services

DCIT 9(1)(1), Mumbai vs. Afcons Infrastructure Ltd, Mumbai

In the result, the appeal of the Revenue and the C

ITA 4798/MUM/2015[2010-11]Status: DisposedITAT Mumbai21 Jun 2024AY 2010-11

Bench: Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri J.D. Mistri / Nitesh Joshi, ARFor Respondent: Shri P. Sudhakar Naik, Sr. DR
Section 115JSection 36(1)(iii)

case was selected for scrutiny and the statutory notices were duly served on the assessee. Since the assessee had international transactions a reference was made to Transfer Pricing Officer (TPO) to determine the Arm's Length Price (ALP) of the international transactions, the assessee has entered into with its Associated ... assessee itself for which the majority of the profit and the benefit went to the assessee. Even it is to be treated as international transaction, then also under the scope and meaning of international transaction as defined in Section 92B- “92B. (1) For the purposes of this section and sections

Triniti Advanced Softwarelabs Private Limited, Hyderabad vs. Income Tax Officers, Ward -2(4), Hyderabad

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

ITA 397/HYD/2021[2016-17]Status: DisposedITAT Hyderabad20 Jun 2024AY 2016-17

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Kranthi, ARFor Respondent: Smt. L. Sunitha Rao, CIT-DR
Section 143(3)

company, engaged in the business of providing ERP software consultancy services to its Associated Enterprise (AE), M/s. Triniti Inc, USA. In view of the international transactions conducted by the assessee with its AE, determination of Arm’s Length Price (ALP) was referred to the learned Transfer Pricing Officer (learned

Applabs Technologies Pvt Ltd (Now Merged With Computer Science Corporation Pvt Ltd ), Hyderabad vs. Dy. Commissioner of Income Tax, Circle-1, Hyderabad

In the result, the appeal of the assessee for the A

ITA 854/HYD/2019[2013-14]Status: DisposedITAT Hyderabad20 Jun 2024AY 2013-14

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Vikram Vijayaraghavan, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 115JSection 143(3)

have erred, in law and facts, by not restricting the value of adjustments to the global profits earned by the Appellant from the international transactions. 12. The learned TPO and the learned AO have erred, in not considering the rectification petition filed by the Appellant in relation to mistake apparent ... transactions relating to provision of corporate guarantee, without appreciating the fact that the said transactions is not covered under the definition of international transaction uls.928 of the Act and that the Page 7 of 26 ITA Nos. 1793 & 1805/Hyd/2017 and 854/Hyd/2019 explanation to section 928 would not apply

Deputy Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Applabs Technologies Pvt. Ltd. (Now Merged With M/S Computer Science India Pvt. Ltd.), Hyderabad

In the result, the appeal of the assessee for the A

ITA 1805/HYD/2017[2012-13]Status: DisposedITAT Hyderabad20 Jun 2024AY 2012-13

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Vikram Vijayaraghavan, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 115JSection 143(3)

have erred, in law and facts, by not restricting the value of adjustments to the global profits earned by the Appellant from the international transactions. 12. The learned TPO and the learned AO have erred, in not considering the rectification petition filed by the Appellant in relation to mistake apparent ... transactions relating to provision of corporate guarantee, without appreciating the fact that the said transactions is not covered under the definition of international transaction uls.928 of the Act and that the Page 7 of 26 ITA Nos. 1793 & 1805/Hyd/2017 and 854/Hyd/2019 explanation to section 928 would not apply

Computer Sciences Corporation India Private Limited (Previously Known As Applabs Technologies Private Limited), Hyderabad vs. Deputy Commissioner of Income Tax, Circle-1(1), Hyderabad

In the result, the appeal of the assessee for the A

ITA 1793/HYD/2017[2012-13]Status: DisposedITAT Hyderabad20 Jun 2024AY 2012-13

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri Vikram Vijayaraghavan, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 115JSection 143(3)

have erred, in law and facts, by not restricting the value of adjustments to the global profits earned by the Appellant from the international transactions. 12. The learned TPO and the learned AO have erred, in not considering the rectification petition filed by the Appellant in relation to mistake apparent ... transactions relating to provision of corporate guarantee, without appreciating the fact that the said transactions is not covered under the definition of international transaction uls.928 of the Act and that the Page 7 of 26 ITA Nos. 1793 & 1805/Hyd/2017 and 854/Hyd/2019 explanation to section 928 would not apply

M/S Centrient Pharmaceuticals India Private Limited, Nawanshahar vs. Additinal/Joint/Deputy/Asstt. C.It, ITO, Neac, Delhi

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

ITA 102/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh18 Jun 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 144

that the assessee company is engaged in manufacturing of intermediaries and bulk drugs. During the period under consideration, the assessee company entered into various international transactions with its Associated Enterprises which were referred during the course of assessment proceedings to the TPO for necessary examination and verification ... assailed the said transfer pricing adjustment. 4. From the perusal of the records, it is noted that the assessee had benchmarked its aforesaid international transaction by applying Transactional Net Margin method as the most appropriate method which was rejected by the TPO wherein he applied CUP method to benchmark

Amplus Power Solutions Private Ltd., Gurgaon vs. ACIT-Circle-1(1), Delhi

In the result, ground no. 1 to 8 of appeal are allowed for statistical purpose

ITA 1213/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Jun 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kediaआअसं.1213/िद"ी/2022 (िन.व. 2017-18) Amplus Power Solutions P. Ltd., 6Th Floor, The Palm Square, Golf Course Extension Road, Sector-66, Gurugram 122102, Haryana ...... अपीलाथ"/Appellant Pan: Aaoca0544J बनाम Vs. The Assessing Officer, National Faceless Assessment Centre, Jurisdictional Assessing Officer-Circle1(1), ..... "ितवादी/Respondent New Delhi अपीलाथ" "ारा/ Appellant By : Shri Nikhil Tiwari "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 05/06/2024 घोषणा क" ितिथ/ Date Of Pronouncement : 13/06/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 29.3.2022 Passed U/S. 143(3) R.W.S. 144B Of The Income Tax Act, 1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Assessee In Appeal Has Raised Nine Grounds. The Ground No. 1 To 8 Of Appeal Are Against Addition Made On Interest On Non Convertible Debentures & Non Compliance Of Directions Of The Dispute Resolution Panel (Drp) By The Transfer Pricing Officer (Tpo)/Assessing Officer (Ao).

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)

length interest rate at 17.03% by the TPO as against the interest rate paid by assessee 14.03%/14.25% would show the international transaction undertaken by the assessee is at arm’s 3 length. Thus, on merits also the TP adjustment made by TPO is liable to be deleted. 4. Shri ... convertible debentures. It is stated that the TPO has considered wrong facts, while computing the TP adjustment for the impugned international transaction and that he has erroneously mentioned that the assessee has paid interest at a rate of 19.30% on the NCDs issued to its AEs, whereas the assessee

Oakton Global Technology Services Centre (India) Private Limited, Hyderabad vs. ITO, Ward-16(3), Hyderabad

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

ITA 309/HYD/2017[2012-13]Status: DisposedITAT Hyderabad12 Jun 2024AY 2012-13

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.309/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2012-13) Oakton Global Technology Vs. Income Tax Officer Services Centre (India) (P) Ltd, Ward 16(3) Hyderabad Hyderabad Pan:Aaaco8824H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bhardwaj, Ca राज" व "ारा/Revenue By:: Smt. Th Vijaya Lakshmi, Dr सुनवाई की तारीख/Date Of Hearing: 10/06/2024 घोषणा की तारीख/Pronouncement: 12/06/2024 आदेश/Order

For Appellant: Shri Ravi Bhardwaj, CAFor Respondent: : Smt. TH Vijaya Lakshmi, DR
Section 143(3)Section 144(5)

undertaking a fresh economic analysis during the course of assessment proceedings and accordingly making an adjustment of Rs 77,411,952 to the international transactions of providing software services to its AE; Rejection of use of multiple year data 2) Rejecting the use of multiple year data and using data ... risk differences 8) Not adjusting the net margins of the comparable companies selected taking into account the functional and risk differences between the international transaction of the Appellant and the comparable companies in accordance with the provisions of Rule 10B(1)(e) of the Rules; Imputing interest on outstanding receivables

Chenniappan Ramadurai, Erode vs. DCIT, Central Circle-2, Coimbatore

In the result the appeal is dismissed

ITA 1337/CHNY/2023[2018-19]Status: DisposedITAT Chennai12 Jun 2024AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1337/Chny/2023 & Ita Nos.1340/Chny/2023 निर्धारण वर्ा /Assessment Years: 2018-19 & Ay-2019-20 Shri Chenniappan Ramadurai, Dy. Commissioner Of Income Tax, No.56, Nms Compound, Erode, Central Circle-2, Coimbatore. Tamil Nadu-638001. [Pan: Aelpr2706M] & Ita Nos.1343/Chny/2023 For Ay 2019-20 Smt. Ramadurai Amutha, No.56, Nms Compound, Erode, Dy. Commissioner Of Income Tax, Tamil Nadu-638001. Central Circle-2, Coimbatore. [Pan: Afvpa4816L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.S.Sridhar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Arv Srinivasan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 30.05.2024 घोषणा की तारीख /Date Of Pronouncement : 12.06.2024

For Appellant: Mr.S.Sridhar, AdvocateFor Respondent: Shri ARV Srinivasan, Addl.CIT
Section 133ASection 147Section 148Section 148(1)Section 250Section 270ASection 270A(6)Section 270A(8)Section 270A(9)

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

Clinasia Labs Private Limited, Hyderabad vs. ITO Ward1(4), Hyderabad

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

ITA 202/HYD/2021[2016-17]Status: DisposedITAT Hyderabad11 Jun 2024AY 2016-17

Bench: Shri Laliet Kumar & Shri Manjunatha G.

For Appellant: Shri Nemichand Sirvi, ARFor Respondent: Shri K. Meghnath Chowhan, DR
Section 143(3)Section 92C

filters. TP Grounds on Receivables 12. The Ld. AO/ Ld. TPO and the Ld DRP have erred by considering outstanding receivables as a separate international transaction. 13. The Ld. AO/ Ld. TPO and the Ld. DRP ought to have appreciated that the receivables arise in the normal course of business ... global customer base through its associate company Maxis IT in USA.” 3. During the year under consideration, the assessee has entered into the following international transactions: Sl.No. Name of the AE International Amount Method transactions (in Rs.) applied 1. Maxis IT Inc, USA Provision of 159494796 TNMM software services