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“specified domestic transaction”

Transfer PricingSection 92BASection 92BA588 judgments

The decision most relied on for specified domestic transaction is CIT v. ITC Ltd. (236 Taxmann 612), cited in 108 judgments on BharatTax.

Leading authorities on specified domestic transaction

CIT v. ITC Ltd.
236 Taxmann 612 · 2016 · High Court
108
citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

CIT v. Godawari Power & Ispat Ltd.
42 Taxmann.com 551 · 2014 · High Court
104
citing judgments

Inter-unit transfer of power by an industrial undertaking eligible for Section 80IA deduction constitutes a specified domestic transaction under Section 92BA, requiring valuation at arm's length. This decision clarifies the application of Section 80IA(8) and transfer pricing regulations for such transactions.

CIT v. Jindal Steel & Power Ltd.
157 Taxmann.com 207 · 2023 · Supreme Court
58
citing judgments

For Section 80IA deductions, the market value of electricity supplied by a captive power plant (eligible unit) to its industrial unit (non-eligible unit) must be computed by comparing prices in the open market and those charged by State Electricity Boards to industrial consumers.

CIT v. Shatrunjay Diamonds
261 ITR 258 · 2003 · High Court
50
citing judgments

The assessee bears the initial burden to maintain and produce authentic documentation under Section 92D and Rule 10D to justify transactions with related parties, especially concerning the arm's length price for such transactions under Section 40A(2)(b). The discharge of this statutory obligation to maintain accurate data is a mandatory requirement of law.

Commissioner of Income Tax v. Gujarat Alkalies Chemicals Limited
395 ITR 247 · 2017 · High Court
49
citing judgments

Deduction under Section 80IA is allowable for captive power generation. The price for calculating this deduction is the rate at which the electricity board supplies power to its consumers, rather than the rate at which power generating companies supply to the electricity board.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad
30 SOT 319 · 2009 · ITAT
26
citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

M/s. Shree Bhagwati Steel Rolling Mills v. C.I.T. Excise & Others
62 Taxmann.com 135 · 2015 · Supreme Court
25
citing judgments

Judgments in M/s. Shree Bhagwati Steel Rolling Mills and M/s. Fibre Boards have overruled earlier decisions, preventing assessees from relying on those overruled precedents.

CIT v. Star Paper Mills Ltd.
172 Taxmann.com 391 · 2025 · High Court
21
citing judgments

The transfer price for intra-group services, specifically the sale of power from a captive power plant to a manufacturing unit, can be benchmarked based on the price at which the manufacturing unit procures power from the State Electricity Board, especially when it reflects a reasonable and arm's length price.

Judgments citing specified domestic transaction

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

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

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

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

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

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

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

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

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

Nirjeet Singh, Delhi vs. ITO Ward 52(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 5151/DEL/2025[2022-23]Status: DisposedITAT Delhi23 Dec 2025AY 2022-23

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year: 2022-23 Shri Nirjeet Singh Vs Ito Ward 52(1) 117, Palika Bazar New Delhi Connaught Place New Delhi- 110001 (Appellant) (Respondent) Pan No. Ablps0458C

For Appellant: Shri K. Sampath, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 250Section 270ASection 270A(9)Section 270A(9)(c)Section 274

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. ” 7. From the discussion in the assessment order and the explanation filed by the assessee during

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

entities, which admitted and undisputedly, has been carried out at arm’s length. Sales made by LHCC and KC to the assessee, being Specified Domestic Transactions (‘SDT’) within the meaning of section 92BA of the Act, have been confirmed to have been made at arm’s length price

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

entities, which admitted and undisputedly, has been carried out at arm’s length. Sales made by LHCC and KC to the assessee, being Specified Domestic Transactions (‘SDT’) within the meaning of section 92BA of the Act, have been confirmed to have been made at arm’s length price

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

entities, which admitted and undisputedly, has been carried out at arm’s length. Sales made by LHCC and KC to the assessee, being Specified Domestic Transactions (‘SDT’) within the meaning of section 92BA of the Act, have been confirmed to have been made at arm’s length price

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

entities, which admitted and undisputedly, has been carried out at arm’s length. Sales made by LHCC and KC to the assessee, being Specified Domestic Transactions (‘SDT’) within the meaning of section 92BA of the Act, have been confirmed to have been made at arm’s length price

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

entities, which admitted and undisputedly, has been carried out at arm’s length. Sales made by LHCC and KC to the assessee, being Specified Domestic Transactions (‘SDT’) within the meaning of section 92BA of the Act, have been confirmed to have been made at arm’s length price

Gunmala Jain, Ajmer vs. Income Tax Officer, WD-2(2), Ajmer

Appeal of the assessee is dismissed

ITA 1262/JPR/2025[2019-20]Status: DisposedITAT Jaipur22 Dec 2025AY 2019-20

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

For Appellant: Sh. Sunil Porwal, CA (Thr.V.C.)For Respondent: Sh. Gautam Singh Choudhary
Section 148Section 250Section 270ASection 80G

income; and 8 Gunmala Jain (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 8. The tax payable in respect of underreported income is prescribed under Sub-Section

Vestas Wind Technology India Pvt. Ltd., Chennai vs. Jci, Co. Range-III, Chennai

In the result, the appeal of the assessee is allowed

ITA 319/CHNY/2025[2008-09]Status: DisposedITAT Chennai22 Dec 2025AY 2008-09

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

For Appellant: Shri. Sriram Seshadri, C.AFor Respondent: Shri. A R V Srinivasan, CIT for Shri. Bipin C.N., CIT
Section 143(3)Section 40A(2)Section 92B

only with effect from AY 2013-14 that the legislature, through the insertion of Section 92BA of the Act, introduced the concept of “specified domestic transactions”. Even then, the scope of Section 92BA of the Act was narrowly circumscribed, applying only in cases where deduction under Section

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2767/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

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), i.e. power conversion charges with uncontrolled transaction i.e., KERC (Karnataka Electricity Regulatory Commission) prices, has to be established in terms of parameters contained ... evidence and documents to support the computation of ALP in relation to the international transactions, assessee had with its AE along with other specified domestic transactions entered into with such AEs. 4. 3. The Ld.TPO from the details furnished noted that, the assessee is a part of JSW group which

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2367/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

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), i.e. power conversion charges with uncontrolled transaction i.e., KERC (Karnataka Electricity Regulatory Commission) prices, has to be established in terms of parameters contained ... evidence and documents to support the computation of ALP in relation to the international transactions, assessee had with its AE along with other specified domestic transactions entered into with such AEs. 4. 3. The Ld.TPO from the details furnished noted that, the assessee is a part of JSW group which

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2366/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Dec 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

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), i.e. power conversion charges with uncontrolled transaction i.e., KERC (Karnataka Electricity Regulatory Commission) prices, has to be established in terms of parameters contained ... evidence and documents to support the computation of ALP in relation to the international transactions, assessee had with its AE along with other specified domestic transactions entered into with such AEs. 4. 3. The Ld.TPO from the details furnished noted that, the assessee is a part of JSW group which

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

ITA 2365/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Dec 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

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), i.e. power conversion charges with uncontrolled transaction i.e., KERC (Karnataka Electricity Regulatory Commission) prices, has to be established in terms of parameters contained ... evidence and documents to support the computation of ALP in relation to the international transactions, assessee had with its AE along with other specified domestic transactions entered into with such AEs. 4.3. The Ld.TPO from the details furnished noted that, the assessee is a part of JSW group which

Krishna Prabha Sundarapandy, Kanchipuram vs. DCIT, Corporate Circle-6(2), Chennai

In the result, the appeal of the assessee is allowed

ITA 2304/CHNY/2025[2022-23]Status: DisposedITAT Chennai17 Dec 2025AY 2022-23

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2304/Chny/2025 िनधा%रण वष% /Assessment Year: 2022-23

For Appellant: Mr. S. Jayakumar, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 143(3)Section 250Section 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.” 6. The contention of the revenue is that the assessee should have noticed the incorrect claim

Satia Industries Limited, Muktsar vs. DCIT/ACIT Circle I, Bathinda

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

ITA 702/ASR/2024[2021-22]Status: DisposedITAT Amritsar16 Dec 2025AY 2021-22

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 143(3)Section 144C(1)Section 144C(2)Section 144C(5)Section 80Section 80GSection 80ISection 92C

purpose of generation of “ Electricity ”and “ Steam ” required in the manufacturing of paper. 3. The assessee during the year has undertaken SDT (specified domestic transactions) with non eligible unit ( paper manufactuting unit ) by transfer of power and steam , and has claimed exemption u/s 80IA ... independent comparable enterprises in similar transactions. 4. The case selected under CASS was referred to the TPO for determination of ALP of specified domestic transactions valued at Rs.62,74,76,383/-, entered into by 3 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 UNIT-1 with the non-specified paper manufacturing

Shri Sureshkumar Harjivanbhai Chandarana, Rajkot vs. The ACIT, Circle - 2 (2) (1), Rajkot

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

ITA 415/RJT/2023[2016-17]Status: HeardITAT Rajkot15 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Durga Dutt, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

Form 3CB and 3CD, it was noticed by the assessing officer that during the year under consideration, the assessee has entered into specified domestic transaction in the nature of purchase with the Page 2 of 11 ITA No. 415/Rjt/2023 A.Y. 16-17 Sureshkumar H. Chandarana wholly owned subsidiary/sister concern named ... amount of Rs.22,94,07,400/-. In this regard assessee was given show -cause, vide letter dated 12.11.2018, as to why the said specified domestic transaction should not be referred to transfer pricing officer (TPO), as per CBDT's Instruction No. 3/2016, for implementation of transfer pricing under the category

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

ITAT in assessee’s own case for A.Y. 2010- 11, A.Y. 2012-13 and A.Y. 2014-15. GROUNDS OF APPEAL - TRANSFER PRICING ADJUSTMENTS SPECIFIED DOMESTIC TRANSACTIONS – ADJUSTMENTS OF Rs.53,80,44,385/- V. Inter-unit Transfer - Technical Textile Business, Kashipur (TTBK) Division – Adjustment of Rs. 8,095/- 32.0 That ... facts & circumstances of the assessee’s case in making the transfer pricing adjustment of Rs. 11,40,07,551/- in respect of specified domestic transaction of transfer or sale of electricity @ 6.35 per unit by the assessee’s WPP unit at Tamil Nadu on wholly unjust, illegal, erroneous, superficial, frivolous

Tata Steel Limited (Successor of Angul Energy Limited), Delhi vs. Assistant Commissioner of Income-Tax, New Delhi

In the result, assessee’s appeal in ITA No

ITA 4171/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2020-21

Section 143(3)Section 144C(13)Section 144C(5)Section 153(3)Section 270ASection 80Section 92BSection 92CSection 93C

illegal and bad in law, since the payment of interest per-se do not qualify as specified domestic transaction in terms of omission of clause (1) of section 92BA(1) of the Act, w.e.f. 01.04.2017. 4. That on facts and circumstances of the case and in law, the Final Assessment ... claimed by the assessee. 4.2 During the previous year relevant to AY 2020-21, the Assessee had entered into specified domestic transactions ['SDT'], details whereof have been disclosed in Form 3CEB and TP study. Observing that in its TP study the assessee had specifically mentioned that the SBI PLR rate