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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

DCIT, Circle-1(1)(1), Ahmedabad vs. Atul Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1774/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 271GSection 92CSection 92DSection 92D(3)

CASS. The Assessing Officer noticed that the assessee had entered into DCIT vs. Atul Limited Page 2 of 11 certain international transactions and specified domestic transactions with its associated enterprises (AEs) which were referred to Transfer Pricing Officer (TPO) for determination of Arm’s Length Price (ALP) of these transactions ... requiring the assessee to produce all the evidences in support of computation of ALP of international transactions as well as the specified domestic transactions, along with transfer pricing study report. The assessee had made only part compliance to the requirements of the TPO and all the details as requisitioned were

Lear Automotive India P. Ltd., Pune vs. Assistant Commissioner of Income Tax, Circle-8, Pune

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17
For Appellant: Shri Dhanesh Bafna &For Respondent: Shri Prakash L. Pathade
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

आयकर अपीलीय अधिकरण “सी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, PUNE BEFORE SHRI R.K. PANDA

Bajaj Housing Finance Limited, Pune vs. ITO, Ward-8(1), Pune

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

ITA 1608/PUN/2025[2017-18]Status: DisposedITAT Pune09 Oct 2025AY 2017-18

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Nikhil Mutha
Section 143(1)Section 250Section 250(6)Section 270ASection 270A(9)

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. 10. It was pointed out that the assessee‘s case does not fall under

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

ITA 573/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

For Appellant: Advocates Percy Perdiwala andFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 143(3)Section 144BSection 144C(3)Section 263Section 80Section 801A

means the arm's length price as defined in clause (ii) of section 92F of such goods or services, if it is a specified domestic transaction referred to in section 92BA.] [(7) Where a deduction under any provision of this Chapter under the heading 'C-Deductions in respect of certain

Panasonic India Private Ltd., Gurgaon vs. Neac, New Delhi

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

ITA 612/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Oct 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

For Appellant: Shri Kanchan Kaushal, AdvFor Respondent: Shri S. K. Jadav, CIT (DR)
Section 143(3)Section 144C(5)Section 92BSection 92C

Trading/ Distribution Segment (ii) Support Services Segment (iii) Manufacturing Segment 4.2. For the year under consideration, the assessee reported the international transactions and specified domestic transactions undertaken by it in Form No 3CEB. Under the Trading / Distribution Segment, the assessee performs trading functions i.e. the assessee purchases consumer electronic goods ... transaction would be apt and accordingly the same was considered as the MAM by the assessee. The assessee while benchmarking the international and specified domestic transactions in its distribution segment, after applying the regular filters on qualitative basis finally selected three comparable companies engaged in similar line of activities

Rajendra Chandrakant Chinchnikar, Pune vs. CIT(A)-11, Pune

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

ITA 1700/PUN/2025[2019-20]Status: DisposedITAT Pune29 Sept 2025AY 2019-20

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Tanzil PadvekarFor Respondent: Shri Milind Debaje, JCIT
Section 133ASection 139(5)Section 143(1)(a)Section 143(2)Section 270ASection 270A(2)(a)Section 270A(9)(e)Section 274Section 69A

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.” 19. As per sub-section (2)(a) to section 270A, a person shall be considered

Income Tax Officer, Jalna vs. Vikram Tea Processor Private Limited, Jalna

In the result, both the appeals filed by the Revenue are dismissed

ITA 685/PUN/2025[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT
Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

transactions entered with AEs. From the various details furnished by the assessee the TPO noted that the assessee has entered into following specified domestic transactions during the year: Sr. No. Name of AEs Description of Specific Amount (In Method domestic transactions INR) 1 ASSAM TEA PURCHASE OF TEA LEAF ... justified in overlooking the saving clause in Section 40A(2)(a), which preserves the applicability of Section 92BA(i) for specified domestic transactions up to AY2013-14. 3. Whether, on the facts and circumstances of the case, the Ld. CIT(A) is correct in relying on judicial precedents that

Income Tax Officer Ward 1 Jalna, Jalna vs. Vikram Tea Processor Private Limited, Jalna

In the result, both the appeals filed by the Revenue are dismissed

ITA 2285/PUN/2024[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT
Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

transactions entered with AEs. From the various details furnished by the assessee the TPO noted that the assessee has entered into following specified domestic transactions during the year: Sr. No. Name of AEs Description of Specific Amount (In Method domestic transactions INR) 1 ASSAM TEA PURCHASE OF TEA LEAF ... justified in overlooking the saving clause in Section 40A(2)(a), which preserves the applicability of Section 92BA(i) for specified domestic transactions up to AY2013-14. 3. Whether, on the facts and circumstances of the case, the Ld. CIT(A) is correct in relying on judicial precedents that

Lotus Footwear Enterprises Limited-India Branch, Tiruvannamalai vs. DCIT, International Tax 1(2), Chennai

In the result all the four appeals of the assessee are allowed

ITA 800/CHNY/2022[2019-2020]Status: DisposedITAT Chennai25 Sept 2025AY 2019-2020

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

For Appellant: Shri. Sriram Seshadri, C.A. &For Respondent: Ms. Pavuna Sundari, C.I.T
Section 10A

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.” 64. Thus, the stand of the lower authorities that the interdependence of units for machinery and materials cannot be a basis

DCIT Central Circle 3(2), Mumbai, Air India vs. Aarti Industries Limited, Mumbai

In the result, the appeal is dismissed

ITA 4869/MUM/2023[2015-2016]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-2016

Bench: Shri Saktijit Dey & Shri Girish Agrawaldy. Cit, Central Circle-3(2) Aarti Industries Limited R. No. 1913, 19Th Floor, 71, Udyog Kshetra, 2Nd Floor, Air India Building, Nariman Point, Vs. Mulund Goregaon Link Road, Mumbai-400 021 Mulund (W), Mumbai-400 080 Pan/Gir No. Aabca 2787 L (Appellant) : (Respondent) Appellant By : Shri Vijay Mehta Respondent By : Shri Rajesh Kumar Yadav Date Of Hearing : 12.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Revenue, Against The Order Dated 30.10.2023 Of Learned Commissioner Of Income Tax (Appeals), Mumbai (‘Ld.Cit(A) For Short), Pertaining To The Assessment Year (A.Y.) 2015-16. 2. Ground No. 1 In The Appeal Reads As Under: 1. On The Facts & Circumstances Of The Case, The Ld. Cit(A) Erred In Deleting The Disallowances Made By The A.O. To Restrict The Deduction U/S. 80Ia Of The Act Despite The Fact That The Issue Has Not Attained Finality & Pending For Adjudication Before The Hon'Ble Supreme Court? – Rs.396,81,798/- 3. Briefly The Facts Are, The Assessee Is A Resident Corporate Entity Engaged In Manufacturing & Sale Of Chemicals, Fertilizers & Intermediaries. For Such Manufacturing Activity, The Assessee Has Set Up A Plant At Plot No. 801/23, Gidc, Phase-Iii

For Appellant: Shri Vijay MehtaFor Respondent: Shri Rajesh Kumar Yadav
Section 133(6)Section 80I

There cannot be any manner of doubt that the transaction relating to sale of electricity between CPP and the manufacturing unit is a Specified Domestic Transaction (‘SDT’ for short) coming within the ambit of section 92BA of the Act. Therefore, in terms with Explanation (ii) under section 80IA ... referred to as "the assessee) for A.Y. 2015-16 for computation of arm's length price in relation to the international transactions and specified domestic transactions was received from DCIT-15(1)(1), Mumbai/ Assessing Officer (hereinafter referred to as "Assessing Officer" or "AO") on 13.09.2017. The AO has made

Sushee Infra & Mining Limited, Hyderabad vs. ACIT., Central Circle-2(2), Hyderabad

In the result, appeal of the Assessee is partly

ITA 1390/HYD/2024[2021-22]Status: DisposedITAT Hyderabad24 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: CA Abhiroop BhargavFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 801ASection 801A(10)Section 92BSection 92C(3)Section 92D

erred in enhancing the income of Assessee by Rs. 1,31,62.27,000 while holding that the Assessee's specified domestic transaction with its associated enterprise ('‘AE") namely Sushee Arunachal Highways Limited pertaining to Ministry of Road Transport Highways project does not satisfy the arm's length principle envisaged under ... AO/Ld. TPO has erred in enhancing the income of Assessee by Rs.12,70,80,000 while holding that the Assessee's specified domestic transaction with its associated enterprise (‘AE’) namely Sushee Prasad JV pertaining to Irrigation & CAD Department, Government of Telangana project does not satisfy the arm's length principle

Titan Company Limited, Hosur vs. ACIT, Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 393/CHNY/2018[2013-14]Status: DisposedITAT Chennai19 Sept 2025AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri T. Surya Narayana &For Respondent: Shri ARV Sreenivasan, CIT
Section 143(3)Section 14ASection 80ISection 92C

Tribunal in the case of DCIT Vs Deepak Industries Ltd [2022] 142 taxmann.com 49 (Kolkata-Trib.). Per contra, the department countered that SDT (Specified Domestic Transactions) provisions applied only from AY 2013–14. For earlier years, ALP (Arm’s Length Price) determination for SDT wasn't legally required. He further ... from Faridabad unit and the same is further subjected to manufacturing processes for production of 3rd & 4th gears as such. During the year, specified domestic transactions between eligible unit and non-eligible unit were made and ALP was determined at 22.10 cr . Similarly Rudrapur unit also does some job work

DCIT, Mumbai vs. Mahindra Homes Pvt Ltd., Mumbai

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 1212/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 Sept 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. S. Sriram a/w Mr. Samyak LohadeFor Respondent: Mr. Pankaj Kumar, CIT-DR
Section 142(1)Section 143(2)

view of international transactions of making interest payment on Compulsorily Convertible Debentures (CCDs) issued to 'SCM Real Estate Singapore Ltd.' Singapore and other specified domestic transaction disclosed in Form No. 3CEB filed by the assessee, the Ld. Assessing Officer(AO) referred the matter for determination of arm's length price ... proposed transfer pricing adjustment amounting to Rs.28,94,33,680/- to the transaction of interest on CCDs. The value of the remaining specified domestic transaction however was considered as at arm's length. The Assessing Officer also made disallowance u/s 57 of the Act in respect of legal and professional

Capacite Infraprojects Limited, Mumbai vs. ACIT/DCIT Central Circle 1(2), Mumbai

The appeal of the assessee are allowed in above terms

ITA 6315/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Sept 2025AY 2017-18

Bench: Shri. Om Prakash Kant & Shri. Raj Kumar Chauhan

Section 115JSection 132Section 153ASection 23(1)Section 250Section 270ASection 36(1)(VA)Section 9

bearing on total income; and (1) 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." ITA No. 6315 & 6309/Mum/2024 CapaciteInfraprojects Limited; A.Y. 2017-18 & 2018-19 From the facts

Capacite Infraprojects Limited, Mumbai vs. ACIT/DCIT Central Circle 1(2) Mumbai, Mumbai

The appeal of the assessee are allowed in above terms

ITA 6309/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Sept 2025AY 2018-19

Bench: Shri. Om Prakash Kant & Shri. Raj Kumar Chauhan

Section 115JSection 132Section 153ASection 23(1)Section 250Section 270ASection 36(1)(VA)Section 9

bearing on total income; and (1) 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." ITA No. 6315 & 6309/Mum/2024 CapaciteInfraprojects Limited; A.Y. 2017-18 & 2018-19 From the facts

Bhel Lcc Society Ltd, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 732/HYD/2025[2017-18]Status: DisposedITAT Hyderabad04 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.732/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Bhel Lcc Society Ltd Vs. Dy.Cit Hyderabad Circle 8(1) Pan:Aaatb6430D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sri Sai Keerthana राज" व "ारा/Revenue By:: Shri Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 01/09/2025 घोषणा की तारीख/Pronouncement: 04/09/2025 आदेश/Order Per Vijay Pal Raothis Appeal By The Assessee Is Directed Against The Order Dated 27/02/2025 Of The Learned Cit (A)-Nfac Delhi, Arising From The Penalty Order Passed U/S 270A Of The I.T. Act For The A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: CA Sri Sai KeerthanaFor Respondent: : Shri Dr. Sachin Kumar, Sr.AR
Section 143(1)Section 143(1)(a)Section 143(3)Section 2Section 270ASection 36

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.” 8. Therefore, the cojoint reading of sub-section (2) & (9) of section 270A leads ... record any receipt in the books of account having bearing on the total income and failure to report any international transaction or specified domestic transactions. In the case in hand, though the Assessing Officer has not enhanced the total income of the assessee while passing the assessment order

Dhara Developers, Shree Vishnudhara Homes vs. Income Tax Officer, Ward 4(2)(1), Income Tax Office, Vejalpur

In the result, appeal filed by the assessee is dismissed

ITA 1833/AHD/2024[2015-2016]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2015-2016

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: NoneFor Respondent: Shri Sher Singh, CIT. DR
Section 250Section 92C

TPOs order under section 92CA.3 of the Act merely on surmises and conjectures.  The appellant has to humbly submit that the specified domestic transaction entered into by the appellant firm with Mrs. Dharmisthaben Thakkar Partner of the firm is in respect of non. agricultural land transferred by Dharmisthaben ... submits that in the present case the appellant firm has rightly determined the arms length price as the cost of acquisition of the specified domestic transaction and hence the upward adjustment of Rs. 832 0480 made to the arms length price of payment made towards the purchase of land from

Avaada Sataramh Private Limited, Noida Gautam Budha Nagar, Up vs. ITO 5(1)(1) G Budh Nagar, Noida, Up

In the result, the appeal being ITA No

ITA 4916/DEL/2024[2021-22]Status: DisposedITAT Delhi03 Sept 2025AY 2021-22

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 115BSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153

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 ... concerns. After due consideration, we observe that assessee has not commenced its business and has not earned any income even the provisions of specified domestic transaction will not apply this year and even the provision of section 115BAB is a provision for availing companies. We observe that when there

Avaada Sustainable Rjproject Private Limited, Gautam Budha Nagar, Up vs. ITO 5 (1)(1), G Budh Nagar, Noida, Up

In the result, the appeal being ITA No

ITA 4884/DEL/2024[2021-22]Status: DisposedITAT Delhi03 Sept 2025AY 2021-22

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 115BSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153

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 ... concerns. After due consideration, we observe that assessee has not commenced its business and has not earned any income even the provisions of specified domestic transaction will not apply this year and even the provision of section 115BAB is a provision for availing companies. We observe that when there

Arusuvai Food Processors Pvt. Ltd., Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 416/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, Advocate
Section 133(6)Section 142(1)Section 143(3)Section 264Section 270ASection 270A(1)Section 270A(9)(a)Section 270A(9)(c)Section 271Section 41(1)

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. 14. The Ld.AR submitted that the AO was bound by law to specify in the notice