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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

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1082/KOL/2025[2021-22]Status: DisposedITAT Kolkata26 Aug 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

generated is partly consumed in the sugar/ distillery plants and partly sold to the State Electricity Board (SEB)/ UPPCL. The assessee is having specified domestic transactions pertaining to the transfer of power to its own undertaking and therefore, case of the assessee was referred to Transfer Pricing Officer ... determination of the arm's length price of the specified domestic transactions of sale of captive power. The learned TPO passed an order under Section 92CA(3) making adjustment on account of transfer of power to its own undertaking that is captively consumed by other undertakings of the assessee company

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1081/KOL/2025[2020-21]Status: DisposedITAT Kolkata26 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

generated is partly consumed in the sugar/ distillery plants and partly sold to the State Electricity Board (SEB)/ UPPCL. The assessee is having specified domestic transactions pertaining to the transfer of power to its own undertaking and therefore, case of the assessee was referred to Transfer Pricing Officer ... determination of the arm's length price of the specified domestic transactions of sale of captive power. The learned TPO passed an order under Section 92CA(3) making adjustment on account of transfer of power to its own undertaking that is captively consumed by other undertakings of the assessee company

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1080/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Aug 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

generated is partly consumed in the sugar/ distillery plants and partly sold to the State Electricity Board (SEB)/ UPPCL. The assessee is having specified domestic transactions pertaining to the transfer of power to its own undertaking and therefore, case of the assessee was referred to Transfer Pricing Officer ... determination of the arm's length price of the specified domestic transactions of sale of captive power. The learned TPO passed an order under Section 92CA(3) making adjustment on account of transfer of power to its own undertaking that is captively consumed by other undertakings of the assessee company

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1079/KOL/2025[2017-18]Status: DisposedITAT Kolkata26 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR
Section 80Section 92C

generated is partly consumed in the sugar/ distillery plants and partly sold to the State Electricity Board (SEB)/ UPPCL. The assessee is having specified domestic transactions pertaining to the transfer of power to its own undertaking and therefore, case of the assessee was referred to Transfer Pricing Officer ... determination of the arm's length price of the specified domestic transactions of sale of captive power. The learned TPO passed an order under Section 92CA(3) making adjustment on account of transfer of power to its own undertaking that is captively consumed by other undertakings of the assessee company

M/S. International Specialty Products (India) Private Limited, Hyderabad vs. Circle 15(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3255/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri P.V.S.S. Prasad, CAFor Respondent: Shri Virabhadra S. Mahajan, Sr. DR
Section 271Section 271(1)(c)Section 92C

extracted below” Explanation 7.-Where in the case of an assessee who has entered into an international transaction or specified domestic transaction defined in section 928, any amount is added or disallowed in computing the total income under sub- section (4) of section 920, then, the amount so added

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

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

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same

Red Hat India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax/ITO/ Circle 15(3)(1), Mumbai

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

ITA 2442/MUM/2022[2018-19]Status: DisposedITAT Mumbai22 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Arun Khodpiaassessment Year : 2018-19 Red Hat India Private Limited, Asst. Commissioner Of A-201, Supreme Business Park, Income Tax/Income Tax Officer, Supreme City, Vs. Circle-15(3)(1), Hiranandani Gardens, Mumbai. Powai, Mumbai-400076. Pan : Aabcr7097N (Appellant) (Respondent) For Assessee : Shri Ajit Jain, For Revenue : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 13-08-2025 Date Of Pronouncement : 22-08-2025 O R D E R Per Amit Shukla, J.M : The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Dated 27/07/2022 Passed By The Acit, Circle 15(3)(1) Mumbai, U/S 144C(13) For The A.Y. 2018-19, In Pursuance To The Directions Issued By The Dispute Resolution Panel-2, Mumbai-2, Dated 15/06/2022 U/S 144C(5).

For Appellant: Shri Ajit JainFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 144C(13)Section 144C(5)

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:-- (a) to (d)…………. (e) transactional net margin ... method, by which,— (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by 'the enterprise or having regard

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

downward adjustment of Rs. 182,23,39,293/-to the arm's length price determined by the Appellant with respect to the Specified Domestic Transaction of transfer of power Eligible unit to the manufacturing unit and, in doing so, has erred in disregarding the arm's length price determined ... case was selected for complete scrutiny through Computer Assisted Scrutiny Selection (in short 'CASS') for the reasons being large specified domestic transaction(s) and large aggregate value of specified domestic transactions in the nature of transfer or acquisition of any goods or services. Accordingly, notice

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)
Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

compute the arm’s length price (ALP) u/s. 92CA of the Act in relation to the international transactions and the specified domestic transactions undertaken by the assessee with its Associated Enterprises (AEs) during the year under consideration. Vide order dated 29.10.2023 u/s. 92CA(3) the TPO proposed total adjustment ... section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same

Assistant Commissioner of Income Tax, Circle-1, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

ITA 435/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Aug 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 121, Adarns Plaza, 60, Feet Road, Tiruppur - 641 602. (अपीलार्थी/Appellant) Vs. Prabhu Spining Mills Private Limited, No. 207 – 86, Mangalam Road, Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. [Pan:Aabcp-0750-E] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यर्थी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख/Date Of Pronouncement : 13.08.2025 Per S. R. Raghunatha, Am : आदेश /Order These Two Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai-16 (In Short “Id.Cit(A)”) Dated 04.10.2024 For Assessment Years 2017-18 & 2018-19 Respectively. Since Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals By The Revenue Are Being Heard Together & Disposed Of By This Consolidated Order. 2. The Appeal Of The Revenue For The Assessment Year 2017-18 Is Taken As The Lead Appeal For Adjudication Of The Issues Involved. The Only Issue Which Has Been Raised In Appeal By The Revenue Is With Regard To Determination Of Quantum Of Deduction U/S.80-Ia Of The Income Tax Act, 1961 (In Short "The Act"). :-2-:

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

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." 18. As regards the above, the Ld.AR submitted that the explanation to section 80- IA(8) provides that for the purposes ... 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. It may be noticed that section 80-IA(8) in its explanation defines market value to be either as per clause

Assistant Commissioner of Income Tax, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

In the result all the grounds raised by the revenue for the A

ITA 433/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

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.” 18. As regards the above, the Ld.AR submitted that the explanation to section 80- IA(8) provides that for the purposes ... 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. It may be noticed that section 80-IA(8) in its explanation defines market value to be either as per clause

Urmila Rajendra Mundra, Ajmer vs. Income Tax Officer, Ward-2(2), Ajmer

In the result grounds raised by the assessee is allowed

ITA 577/JPR/2025[2022-23]Status: DisposedITAT Jaipur01 Aug 2025AY 2022-23

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Sunil Porwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 250Section 270ASection 270A(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 Thus “CAPITALISATION OF INTEREST PAID TO BANK DURING CONSTRUCTION PERIOD” is neither any expenditure Nor “Unproved ... 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. 270AA. Immunity from imposition of penalty, etc. (1) An assessee may make an application

Deputy Commissioner of Income Tax-1(1), Raipur vs. C. G. Ispat Private Limited, Raipur

ITA 95/RPR/2025[2014-15]Status: DisposedITAT Raipur30 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 95/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 147Section 250Section 92BSection 92C

order in as much as provisions of Section 92BA(i) of the Act, 1961 having been amended vide Finance Act, 2017 to exclude specified domestic transactions contained in Sec. 92BA(i) of the Act from the purview of Transfer Pricing Regulations, the findings of Ld. CIT(A) qua the said ... submitted that the issue of upward adjustment amounting to Rs. 6,16,68,732/- being 10% of aggregate value of specified domestic transaction made vide order u/s 92CA(3) of the Act dated 25.10.2017 proposed by the TPO, which thereafter has been added to the taxable income of assessee

Deputy Commissioner of Income Tax- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerly Ut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 532/MUM/2025[2012-13]Status: DisposedITAT Mumbai30 Jul 2025AY 2012-13

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

Section 37Section 92F

reference to quantum and value has been reproduced hereunder for ready reference. "(d) the nature and terms (including prices) of international transactions [or specified domestic transactions] entered into with each associated enterprise, details of property transferred or services provided and the quantum and the value of each such transaction

Fedex Express Transportation and Supply Chain Services (India) Private Limited, Mumbai vs. ACIT 1(3)(1), Mumbai

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

ITA 4783/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 144Section 144BSection 144C(1)Section 144C(13)Section 92CSection 92C(3)

extent to which reliable and accurate adjustments can be made to account for differences, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transaction or between the enterprises entering into such transactions and the nature, extent and reliability of assumptions required to be made ... purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction for a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:-- (a) to (d)............ (e) transactional net margin

M/S. Laxmi Organic Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

ITA 4782/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Percy Pardiwala, Sr. Advocate andFor Respondent: Ms. Neena Jeph, CIT DR
Section 144C(5)Section 80I

under section 80IA in the computation of income, and left it wholly intact, the arm's length price adjustments in respect of the specified domestic transactions could not have affected the computation of income in any other manner whatsoever. 4. On the facts and in the circumstances of the case ... adjustments in respect of the CUP inputs and which permits adjustments in respect of "differences, 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 price in the open market" only

Creative Ashtech Power Projects Pvt. Ltd., Mumbai vs. DCIT, Circle-14(1)(2), Mumbai

In the result, the appeal is dismissed

ITA 1587/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Jul 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarcreative Ashtech Power V/S. Deputy Commissioner Of Projects Private Limited, 7Th बनाम Income Tax, Circle– Floor, Raheja Point 1, Opp. 14(1)(2), Room No. 455, Vakola Market Nehru Road, Aayakar Bhavan, M.K. Santacruz (East), Mumbai– Marg, Mumbai – 400020, 400055, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcd1054F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Jitendra Sanghvi,ARFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 143(3)Section 270ASection 270A(9)Section 270A(9)(e)

bearing on total income; (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.” 7.1 It is evident that the assessee has not shown above income from Foreign Exchange gains

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

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

ITA 2458/MUM/2015[2010-11]Status: DisposedITAT Mumbai16 Jul 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Amol MahajanFor Respondent: Shri Ajay Chandra, CIT-DR
Section 143(3)Section 144CSection 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

Deputy Commissioner of Income-Tax, Circle - 1(1), Pune vs. M/S. IAC International Automotive India Pvt.Ltd, Pune

In the result, the appeal of the Revenue is dismissed

ITA 749/PUN/2022[2013-14]Status: DisposedITAT Pune08 Jul 2025AY 2013-14

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Darpan KirpalaniFor Respondent: Shri Madhukar Anand
Section 143(2)Section 92Section 92C

section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same

Deputy Commissioner of Income Tax, Chennai vs. Ashok Leyland Limited, Chennai

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

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

were benchmarked to the prices at which same products were sold in market to the customers. These transactions being in the nature of specified domestic transactions u/s 92BA of the Act were referred for transfer pricing scrutiny and the TPO in the order passed u/s 92CA ... found these specified domestic transactions to be at arm's length and no adverse inference was drawn u/s 80-IA(8) of the Act. Having regard to these contemporaneous facts, we find merit in the plea of the Ld. AR of the assessee that, when the manner of revenue recognition