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“most appropriate method”

Transfer PricingSection 92CSection 92C1,345 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

secured by bidding on IEX would have a significant bearing on the price of power. 53. As noted above, the CUP method is an appropriate method only in cases where there is sufficient degree of identity between the tested transactions and comparable uncontrolled transactions. The CUP method cannot be applied ... basis point as against which the AO/TPO applied LIBOR + 400 basis points. The assessee has benchmarked the transactions using other method as most appropriate method. 29. During the course of hearing, the ld. AR submitted that this issue is covered by assessee’s own case

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

domestic transaction relating to transfer of steam from eligible captive power unit to non-eligible units. The assessee applied ‘Other Method’ as the most appropriate method to benchmark the said transaction of transfer of steam at its cost of production without any mark-up on the same. 5. However

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

appellate proceedings, the ld. CIT(A) noted that the Transfer Pricing Officer has followed Transactional Net Margin Method (TNMM) as most appropriate method and rightly made the adjustments by selecting suitable comparables considering the size and nature of business of comparables as against the Comparable Uncontrolled Price Method (CUP) followed ... from Associated Enterprises (AE) and the same should have been accepted by the AO. It is clear from records that TNMM is the Most Appropriate Method (MAM) for the Appellant's case and the TPO/ AO has rightly made the adjustment on objective basis by selecting suitable comparables relevant

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

appellate proceedings, the ld. CIT(A) noted that the Transfer Pricing Officer has followed Transactional Net Margin Method (TNMM) as most appropriate method and rightly made the adjustments by selecting suitable comparables considering the size and nature of business of comparables as against the Comparable Uncontrolled Price Method (CUP) followed ... from Associated Enterprises (AE) and the same should have been accepted by the AO. It is clear from records that TNMM is the Most Appropriate Method (MAM) for the Appellant's case and the TPO/ AO has rightly made the adjustment on objective basis by selecting suitable comparables relevant

MERIT DATA AND TECHNOLOGY PRIVATE LIMITED,CHENNAI vs. THE INCOME TAX OFFICER, CORPORATE WARD 4(1) CHENNAI, CHENNAI

In the result, the appeal of the assessee is partly allowed and the stay application of the assessee is dismissed as infructuous

ITA 958/CHNY/2026[2022-23]Status: DisposedITAT Chennai12 Mar 2026AY 2022-23

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.958/Chny/2026 & Sa No.74/Chny/2026 (Arises In Ita No.958/Chny/2026) िनधा%रण वष% /Assessment Year: 2022-23 M/S. Merit Data & Technology Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-4(1), Sp 52, 3Rd Street, Ambattur Industrial Chennai. Estate S.O., Ambattur, Tiruvallur – 600 058. Pan: Aadcl 8191M

For Appellant: Mr. K. Prasanna, C.A )*For Respondent: Mr. ARV Sreenivasan, CIT
Section 143(3)

facts pertaining to the impugned TP adjustment is that in the TP study, the assessee has used transaction net margin method as the most appropriate method. The assessee has computed its PLI based on OP/TC and for the year under consideration the margin of the assessee was arrived

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BENGALURU vs. ANALOG DEVICES INDIA PRIVATE LIMITED, BENGALURU

In the result, the Cross Objection is dismissed as infructuous

ITA 2074/BANG/2024[2011-12]Status: DisposedITAT Bangalore12 Mar 2026AY 2011-12
Section 250

Sales Support Activities (MSS) to its AEs. The assessee\nbenchmarked its international transactions under SWD Segment & MSS\nSegment by adopting TNMM as the most appropriate method. The\nassessee worked out the PLI as OP/TC for both segments, which arrived\nat 10.89% and 10.12% respectively.\n\n5.\nThe assessee

KEWAL KRISHAN, CHANDIGARH,CHANDIGARH vs. JOA DCIT/ACIT/JCIT(OSD)(CENTRAL CIRCLE) 1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1275/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

KEWAL KRISHAN CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) (CENTRAL CIRCLE) 1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1274/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-22
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

KEWAL KRISHAN, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT JCIT (OSD)(CENTRAL CIRCLE)-1, CHANDIGARH., CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1273/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH ,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1272/CHANDI/2025[2023-2024]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-2024

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH , CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1271/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh10 Mar 2026AY 2022-2023
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT (OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1270/CHANDI/2025[2021-2022]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

CHANDIGARH ROYALE CITY PROMOTERS PRIVATE LIMITED, CHANDIGARH,CHANDIGARH vs. JAO DCIT/ACIT/JCIT(OSD) CENTRAL CIRCLE-1, CHANDIGARH, CHANDIGARH

In the result, all the above appeals are partly allowed

ITA 1269/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-2021

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

page 121 of the assessment order and finally held, that it is a case where the application of net profit rate would be most appropriate method, after analysing all the seized material and working submitted by the assessee of the complete seized material in all the respective assessment years. This

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18
For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR
Section 56(2)(vii)Section 56(2)(viib)

novel medical diagnostic products relating to\ndiabetes and pregnancy and the same was duly certified by a Chartered\nAccountant as being the most appropriate method for valuing a newly\nstarted company as it has very little or no capital base.\nA) Basis for valuation:\nThe assessee has submitted the data

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

Income Tax Appeal No. 126 of 2023, dated 28 July 2023), where the Court held that once the TPO accepts TNMM as the most appropriate method for benchmarking a set of international transactions, it is not open to segregate and benchmark an individual element such as royalty, under a different ... transfer pricing study report, the assessee has aggregated all international transactions including payment of royalty and benchmarked them applying CPM as the most appropriate method. It is evident, the Transfer Pricing Officer has accepted the benchmarking of all international transactions under CMP except the payment of royalty. It further transpires

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

Income Tax Appeal No. 126 of 2023, dated 28 July 2023), where the Court held that once the TPO accepts TNMM as the most appropriate method for benchmarking a set of international transactions, it is not open to segregate and benchmark an individual element such as royalty, under a different ... transfer pricing study report, the assessee has aggregated all international transactions including payment of royalty and benchmarked them applying CPM as the most appropriate method. It is evident, the Transfer Pricing Officer has accepted the benchmarking of all international transactions under CMP except the payment of royalty. It further transpires

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

without appreciating the fact that, DCF method adapted in the valuation report to value equity of M/s Intas Lifesciences Pvt. Ltd., was not the appropriate method of valuation of shares, as entire cash flow of M/s Intas Lifesciences Pvt. Ltd is from the assessee company and also in comparable company ... instant case, 96% shareholding of M/s Intas Lifesciences Pvt. Ltd was held by the assessee company and its shareholders, hence the most appropriate method to value equity of M/s Intas Lifesciences Put. Ltd would be Net Asset Value Method, considering the facts of this case in particular. 7) Whether

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

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

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22
For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)
Section 143(3)

Development Segment (SWD)\n(ii) Software Distribution Segment (SDS)\n5.1 The assessee benchmarked its transaction under SWD & SDS\nsegment by adopting TNNM as most appropriate method and further PLI\nas OP/OC which arrived at 18.80% for SWD and 8.64% for SDS\nsegment. The assessee for the comparability analysis under

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

addition to other factors such as nature of transaction, degree of comparability, etc. one of the key criteria for determination of the most appropriate method is the availability, coverage and reliability of data necessary for application of the method. Accordingly, to determine whether any one of the transfer pricing methods ... method (over other methods) would provide a more accurate result of ALP. Based on the above discussion, the CUP method was considered as most appropriate method to benchmark the above transaction. 7.2.1.4 Selection of comparable period xx xx Accordingly, all the loan transactions entered during the financial year 1 April

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)

Assessee-company had earned an operating margin\n(OP/OC) of 14.52% in respect of SWD Segment.\nThe Assessee had adopted TNMM as the most appropriate method\nwith Operating Profit/Total Cost (OP/TC) as the Profit Level Indicator\n(PLI) for benchmarking the SWD Segment. The arm's-length range\ndetermined ... length price of the International transactions\nentered into by the taxpayer is computed as under:\n22.1. Method Used:\nTNMM is used as the most appropriate method both by the\ntaxpayer as well as the TPO.\n22.2 Comparable:\nThe comparable are as discussed above. The computation of\nthe

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