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“specified domestic transaction”

Transfer PricingSection 92BASection 92BA588 judgments

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 5560/DEL/2024[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(1)Section 143(1)(a)Section 143(3)Section 80Section 80ISection 92C

reference under section 92CA of the Act was made to the TPO for determination of ALP in respect of international transactions and specified domestic transactions. Several transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before ... issue involved is the transfer pricing adjustment of Rs 28,00,16,724/- to the arm’s length price (ALP) of the specified domestic transaction relating to transfer of electricity from eligible captive power unit to non-eligible units. Briefly stated the assessee owns various captive power plants for production

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

scrutiny and a reference under section 92CA of the Act was made to the TPO for determination of ALP in respect of specified domestic transactions. Certain transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before ... erred in law and facts and in circumstances of the case in making an adjustment of ₹107,01,24,795/- in respect of specified domestic transaction of transfer of steam by eligible power unit to non-eligible unit [at its cost of production] by treating its arm's length price

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

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

ITA 54/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

order of the ld. CIT(A) in upholding the addition of Rs. 50,64,220/- as made by the AO/TPO for the specified domestic transactions entered into by the assessee. ITA No. 53 & 54/GTY/2025 Mahalaxmi Continental Ltd. Vs DCIT/ACIT 3. At the time of hearing, the ld. Counsel ... assessee submitted that the AO has no jurisdiction to refer the issue of determination of Arms Length Price of the specified domestic transactions of purchases with the AEs to the transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective effect

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

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

ITA 53/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

order of the ld. CIT(A) in upholding the addition of Rs. 50,64,220/- as made by the AO/TPO for the specified domestic transactions entered into by the assessee. ITA No. 53 & 54/GTY/2025 Mahalaxmi Continental Ltd. Vs DCIT/ACIT 3. At the time of hearing, the ld. Counsel ... assessee submitted that the AO has no jurisdiction to refer the issue of determination of Arms Length Price of the specified domestic transactions of purchases with the AEs to the transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective effect

TEHMINA K KATRAK CHARITABLE TRUST ,MUMBAI vs. ITO WARD 2(4), MUMBAI

ITA 549/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22
Section 11Section 119Section 139Section 154Section 92E

extended to 15th\nFebruary, 2022;\n3. The due date of furnishing of Report from an Accountant by persons\nentering into international transaction or specified domestic transaction\nunder Section 92E of the Act for the Previous Year 2020-21, which was\n31st October 2021, as extended to 30th November

ACIT, CIRCLE-6(1)(2), MUMBAI, MUMBAI vs. ASR MULTIMETALS PVT. LTD., MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 119/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal(Hybrid Hearing) Assistant Commissioner Of Asr Multimetals Pvt. Ltd. Income Tax 6(1)(2), Mumbai Vs 202, Steel Center, Iron Market, Room No. 506, 5Th Floor, Mumbai – 400009. Aayakar Bhavan, M. K. Road, Mumbai – 400020. [Pan No. Aaeca9439L] Appellant / Revenue Respondent / Assessee Assessee By Shri Sunil Talathi, Ca (Virtually Present) Revenue By Shri Bhagirath Ramawat (Sr. Dr) Date Of Hearing 11.03.2026 Date Of Pronouncement 11.03.2026

Section 133(6)Section 254(1)

case and in law, the Ld. CIT(A) is justified in allowing the internal CUP adopted by the assessee for benchmarking of Specified Domestic Transactions of inter unit transfer of power and rejecting external CUP adopted by TPO ignoring following crucial facts: a) The assessee had adopted Internal ... consuming unit as a tested party and rejecting TPO's act of selecting the power generating company as tested party for benchmarking of Specified Domestic Transactions of inter unit transfer of power ignoring the comparability factor and FAR analysis. 3. The Appellant prays that the order

M/S. AVM PRODUCTIONS,CHENNAI vs. ACIT, NON CORPORATE CIRCLE-20(1), CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 2359/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

Section 270Section 270A

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. M/s. AVM Productions :: 9 :: 7. As noted, the AO has not given any reason

SHREE NATH KRIPA FOODS PRIVATE LIMITED,RIICO INDUSTRIAL AREA, NOKHA vs. INCOME TAX OFFICER, ITO, WARD, NOKHA

In the result, the appeal is allowed for the statistical purpose

ITA 198/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Feb 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleshree Nath Kripa Foods Pvt. Ltd. Income Tax Officer, Ito, Ward F-41 & F-42, Riico Industrial Bikaner Area, Nokha, Bikaner - 334803 Pan No. Aamcs 9124 Q Assessee By Shri Amit Kothari, Ca (Physical) Revenue By Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 30.01.2024 With Respect To Assessment Year 2016-17 Challenging Therein The Order Passed By The Ld. Cit(A) Ex-Parte In Violation Of Principles Of Natural Justice.

Section 143(3)Section 144Section 144cSection 92CSection 92E

Under the facts and circumstances of the case the Ld. AO has erred in referring matter to TPO for determination of ALP of Specified Domestic Transactions contrary to the CBDT guidelines ignoring that the appellant 2 Asst. Year: 2016-17 has duly furnished report of an accountant in prescribed Form ... adjustment in ALP for payment of goods, salary and interest to relative and associates enterprises with whom specified domestic transaction had taken place. 5. Under the facts and circumstances of the case the Ld. AO has grossly erred in confirming ex-parte order of TPO passed under section 92CA

ACIT, CIRCLE-1(1)(1), VADODARA vs. FARMSON PHARMACEUTICAL GUJARAT PRIVATE LIMITED, VADODARA

In the result, the appeal of the Revenue is dismissed

ITA 1835/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2015-16

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 115JSection 144(1)Section 37Section 92BSection 92CSection 92E

existent of such provision in the Act, the action of the A.O. in referring the case to TPO for determining the ALP of specified domestic transaction is without jurisdiction and therefore not valid. Thus, the CIT(A) has rightly deleted the addition. Hence, the appeal of the Revenue is dismissed

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

Transactional Net Margin Method, by which,-\n(i) the net profit margin realised by the enterprise from an\ninternational transaction or a specified domestic transaction\nentered into with an associated enterprise is computed in\nrelation to costs incurred or sales effected or assets\nemployed or to be employed

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

ITA 533/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

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

company was selected for scrutiny Page. No 2 I.T.A.No.533/VIZ/2024 Teejay India Private Limited assessment for verification of certain issues, viz. (i) large specified domestic transactions; and (ii) international transactions in respect of intangible property. 3. During the course of the assessment proceedings, the AO, made a reference

ACIT, MUMBAI vs. DNJ CREATION LLP, MUMBAI

In the result, grounds of appeal raised by revenue are dismissed

ITA 4329/MUM/2025[2017]Status: DisposedITAT Mumbai13 Feb 2026

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing)

Section 10ASection 143(3)Section 254(1)Section 92C

minus 2.94%) on the entire operating revenue of INR 124,23,52,396/- instead of restricting the adjustment only to the specified domestic transactions of INR 26,53,96,346/- 3. In the facts and circumstances of the case and in law, the Hon'ble CIT(A) erred ... 270/Mum/2025 DNJ Creation LLP 10AA of the Act, its transaction of purchase of cut and polished diamond from its diamond division qualifies for Specified Domestic Transaction (SDT) and accordingly transfer pricing regulations are applicable to the transaction. The assessee has benchmarked its transaction of purchase and cut polished diamonds

S S R S MEM EDU SOCIETY,SOUTH EXTENSION PART-II vs. ACIT, NEW DELHI

In the result, impugned order is set aside and appeal of the assessee is\nallowed

ITA 3064/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: \nShri V.K Tulsian, Chartered Accountant (Virtual)For Respondent: \nShri Om Prakash, Sr. DR
Section 270A

total income;\nand\n(f) failure to report any international transaction or any transaction deemed to be an\ninternational transaction or any specified domestic transaction, to which the provisions\nof Chapter X apply.\n5. The AO neither, at the time of initiating penalty nor, anywhere in the penalty\norder

MYUMGHWA AUTOMOTIVE INDIA PVT. LTD.,KANCHIPURAM vs. ITO, CORPORATE WARD-4(1), CHENNAI

The appeal of the assessee stands allowed

ITA 2660/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Feb 2026AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Ms. Divya Abhishek, C.AFor Respondent: Shri. K. Ilayaraja, Addl. CIT
Section 143(2)Section 143(3)Section 250Section 270ASection 36(1)(va)

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. 13. A claim which is duly disclosed in the return of income but subsequently disallowed

MAHARASHTRA STATE ELECTRICITY TRANSMISSION COMPANY LIMITED,MUMBAI vs. ITO CIRCLE 14(1)(1), MUMBAI

ITA 2552/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

case of the Assessee was selected for scrutiny. During the course of proceedings, the Assessing Officer noted that the Assessee had large Specified Domestic Transactions amounting to INR.2716,57,40,718/- with its Associated Enterprises (AEs). Accordingly, a reference was made under section 92CA of the Act the Transfer Pricing ... Officer (TPO) for determination of Arm's Length Price (ALP) of Specified Domestic Transactions. The Transfer Pricing Officer passed the order, dated 19/03/2019, under Section 92CA(3) of the Act, accepting the ALP of Specified Domestic Transactions reported by the Assessee. Thereafter, the Assessing Officer proceeded to frame assessment under

JCIT(OSD)-14(1)(1), MUMBAI vs. MAHARASHTRA STATE ELECTRICITY TRANSMISSION CO. LTD., MUMBAI

ITA 2093/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhao VichoreFor Respondent: Shri Solgy Jose
Section 143(3)Section 14A

case of the Assessee was selected for scrutiny. During the course of proceedings, the Assessing Officer noted that the Assessee had large Specified Domestic Transactions amounting to INR.2716,57,40,718/- with its Associated Enterprises (AEs). Accordingly, a reference was made under section 92CA of the Act the Transfer Pricing ... Officer (TPO) for determination of Arm's Length Price (ALP) of Specified Domestic Transactions. The Transfer Pricing Officer passed the order, dated 19/03/2019, under Section 92CA(3) of the Act, accepting the ALP of Specified Domestic Transactions reported by the Assessee. Thereafter, the Assessing Officer proceeded to frame assessment under

M/S GURU NANAK RICE MILLS,NAKODAR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, NAKODAR

ITA 105/ASR/2019[2014-15]Status: DisposedITAT Amritsar05 Feb 2026AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

For Appellant: Sh. Ashray Sarna (CA) – Ld. ARFor Respondent: Sh. Farat Khan (CIT) – Ld. DR
Section 143(3)Section 271GSection 92C

order is an ex-parte order. 3. The assessee is engaged in trading of rice and allied products. Since the assessee carried out specified domestic transactions of purchase of rice from Associated Enterprises, the same was referred u/s 92CA for determination of Arm’s Length Price. The assessee failed

M/S GURU NANAK RICE MILLS,NAKODAR vs. DY. COMMISSIONER OF INCOME TAX, NEW DELHI

ITA 104/ASR/2019[2013-14]Status: DisposedITAT Amritsar05 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

For Appellant: Sh. Ashray Sarna (CA) – Ld. ARFor Respondent: Sh. Farat Khan (CIT) – Ld. DR
Section 143(3)Section 271GSection 92C

order is an ex-parte order. 3. The assessee is engaged in trading of rice and allied products. Since the assessee carried out specified domestic transactions of purchase of rice from Associated Enterprises, the same was referred u/s 92CA for determination of Arm’s Length Price. The assessee failed

M/S GURU NANAK RICE MILLS,NAKODAR vs. INCOME TAX OFFICER, NAKODAR

ITA 103/ASR/2019[2013-14]Status: DisposedITAT Amritsar05 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

For Appellant: Sh. Ashray Sarna (CA) – Ld. ARFor Respondent: Sh. Farat Khan (CIT) – Ld. DR
Section 143(3)Section 271GSection 92C

order is an ex-parte order. 3. The assessee is engaged in trading of rice and allied products. Since the assessee carried out specified domestic transactions of purchase of rice from Associated Enterprises, the same was referred u/s 92CA for determination of Arm’s Length Price. The assessee failed

DCIT, MUMBAI vs. TRENT LIMITED, MUMBAI

In the result, these grounds of appeal are

ITA 5242/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing) Trent Limited Dcit-2(3)(1), Mumbai 552, 5Th Floor, Aayakar Bhavan, Bombay House, Mumbai, Vs Maharashtra – 400001. Maharishi Karve Road, [Pan: Aaacl1838J] Mumbai-400020. Appellant / Assessee Respondent / Revenue Dcit-2(3)(1), Mumbai Trent Limited 552, 5Th Floor, Aayakar Bhavan, Vs G Block, Plot No. C 60, Trent House, Maharishi Karve Road, Beside City Bank, Bandra K Complex, Mumbai-400020. Bandra E Mumbai – 400051. [Pan: Aaacl1838J] Appellant / Revenue Respondent / Assessee

Section 115JSection 143(3)Section 153Section 254(1)Section 40A(2)Section 92BSection 92C

Officer (TPO) under section 92CA of the Act, thereby upholding that the transaction with Fiora Services Limited would fall within the ambit of specified domestic transactions under section 92BA read with section 40A(2) of the Act and therefore the Assessing Officer was correct in passing the order within ... section 115JB. The case was selected for scrutiny. During assessment, the assessing officer noted that assessee has reported international transaction as well as specified domestic transaction in its transfer pricing study report. Consequent upon a reference under section 92CA(3) was made for computation of arm’s length price with

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