“specified domestic transaction”

Trent Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(3)(1), Mumbai

In the result, these grounds of appeal are

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

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

Dy. Commissioner of Income Tax 5(2)(1), Mumbai vs. Jsw Steel Coated Products Limited, Mumbai

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

case and in law, the Ld. CIT(A)is correct in not appreciating the fact and position of law that comparability of the specified domestic transaction (SDT) with uncontrolled transaction has to be established in terms of parameters contained in Rule 108(2), by which the price charged ... length price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA 30. As could be seen from a reading of the said Explanation, clause (i) is verbatim same to the earlier Explanation. What

DCIT-5(2)(1), Mumbai, Aayakar Bhavan vs. Jsw Steel Coated Products Limited, Mumbai

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

case and in law, the Ld. CIT(A)is correct in not appreciating the fact and position of law that comparability of the specified domestic transaction (SDT) with uncontrolled transaction has to be established in terms of parameters contained in Rule 108(2), by which the price charged ... length price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA 30. As could be seen from a reading of the said Explanation, clause (i) is verbatim same to the earlier Explanation. What

Maersk Tankers India Private Limited, Mumbai vs. The Assessment Unit, Income-Tax Department, Mumbai

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

deemed 4 ITA No. 8376/Mum/2025 & SA No. 158/Mum/2025 Maersk Tankers India Private Limited international transaction under section 92B(2), nor a specified domestic transaction under section 92BA. The assessee also challenged the validity of the reference to the TPO, the rejection of the independent valuation report, and the reworking ... Assessment Unit grossly erred in concluding that a transaction between two Indian resident group entities, merely because it was not reported as a “Specified Domestic Transaction”, becomes an_ international transaction. It was submitted that the Act does not contemplate such an interpretation, and that absence of reporting

National Institute of Construction Management and Research, Mumbai vs. DCIT(Exem), Circle - 2, Mumbai

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

Viraj Solar Maharashtra Private Limited, Andheri East West Flyovermumba vs. ITO 8(3)(1), Mumbai, Aayakar Bhawan

In the result, the appeal being ITA No

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Viraj Solar Maharashtra Private Limited Ito, 8(3)(1), Mumbai 406, Hubtown Solaris, N.S. Phadke Marg, Vs Aayakar Bhawan, Mumbai, Andheri East West Flyover, Mumbai, Maharashtra. Maharashtra-400069. [Pan:Aadvc 4415 A] Appellant / Assessee Respondent / Revenue

that the transactions as made by the appellant with his Associate Enterprises namely M/s. Avaada MHBuldhana Private Limited are in the nature of specified domestic transaction as per the provisions of 92BA of the Income Tax Act, 1961 for the reasons mentioned in the impugned order or otherwise ... return of income on 15.03.2022 declaring loss of Rs.10,50,200/-. The case was selected for scrutiny under CASS for the reason “Large specified domestic transactions”. The AO referred the matter to the AO, Technical Unit to determine Arm’s Length Price (ALP) in respect of international transactions. During assessment

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

adjusted to take into account the functional and other differences, including differences in accounting practices, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of gross profit margin ... with non-Associated Enterprises, Chapter X of the Act is not triggered to make adjustment to considerations received or paid unless they are Specified Domestic Transactions. The transaction with non-Associated Enterprises are presumed to be at arm's length as there is no relationship which is likely to influence