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“CUP method”

Transfer PricingSection 92CSection 92C828 judgments

The decision most relied on for CUP method is Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT (44 SOT 391), cited in 39 judgments on BharatTax.

Leading authorities on CUP method

Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT
44 SOT 391 · 2011 · ITAT
39
citing judgments

The Comparable Uncontrolled Price (CUP) method is preferred over indirect methods for determining the arm's length price in transfer pricing matters, especially for royalty payments.

Asstt. CIT v. MSS India (P.) Ltd.
32 SOT 132 · 2009 · ITAT
26
citing judgments

The Comparable Uncontrolled Price (CUP) method is preferred when comparable transactions with third parties are available to determine if transfer prices are at arm's length. Transactional profit methods are considered methods of last resort.

10 Glenmark Pharmaceuticals Ltd. v. Addl. CIT
43 Taxmann.com 191 · 2014 · Reported
26
citing judgments

Bank guarantee commission prices are not comparable to external CUPs for benchmarking corporate guarantees in transfer pricing.

CIT v. Eicher Motors Ltd.
293 ITR 464 · 2007 · High Court
22
citing judgments

Expenditure by way of royalty is an allowable revenue deduction if it is for a limited license to use know-how, where the assessee is not vested with proprietary rights. This is especially true if the payment falls within a reasonable range based on comparable transactions.

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.

ACIT v. MSS India (P) Ltd.
123 TTJ 657 · 2009 · ITAT
16
citing judgments

A transfer pricing officer (TPO) must justify preferring one method over another, such as the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method, by demonstrating fallacies in the application of the preferred standard method.

Star India P. Ltd. v. ACIT
317 ITR 292 · 2009 · ITAT
16
citing judgments

When analyzing international transactions, separate classes of transactions, such as fees for technical know-how, use of trademarks, and procurement, must be analyzed individually, as each impacts profits. Aggregation of such transactions is not permissible.

Gharda Chemicals Ltd. v. Oy. CIT
39 SOT 93 · 2010 · ITAT
16
citing judgments

The Comparable Uncontrolled Price (CUP) method is the most preferred method for determining arm's length price in international transactions, but it requires a high degree of comparability. If comparables are not identical, the CUP method may not be applicable unless another method is proven to be more reliable in the specific fact situation.

Judgments citing CUP method

Assistant Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. M/S Schaeffler India Ltd, Vadodara

ITA 2018/AHD/2025[2007-08]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2007-08

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

Section 143(3)Section 92C

passed u/s. 92CA of the Act. The DRP, Ahmedabad vide order dated 27-9-2010 held that the royalty is to be benchmarked using CUP method and royalty at the rate of 2.3% is the correct ALP. Therefore, as against addition of Rs.350.56 lakh on account of royalty payment made ... that in many decisions referred in the remand report it has been held that the ALP of royalty payment should be determined by using CUP method is not acceptable at this stage. The TPO has not pointed out any defect in the ALP determined by the appellant using TNMM considering

Assistant Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. M/S Schaeffler India Ltd, Vadodara

ITA 2017/AHD/2025[2006-07]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2006-07

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

Section 143(3)Section 92C

passed u/s. 92CA of the Act. The DRP, Ahmedabad vide order dated 27-9-2010 held that the royalty is to be benchmarked using CUP method and royalty at the rate of 2.3% is the correct ALP. Therefore, as against addition of Rs.350.56 lakh on account of royalty payment made ... that in many decisions referred in the remand report it has been held that the ALP of royalty payment should be determined by using CUP method is not acceptable at this stage. The TPO has not pointed out any defect in the ALP determined by the appellant using TNMM considering

Firstrand Bank Limited, Mumbai vs. The Assistant Comm. of Income Tax-Circle-2(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2502/MUM/2022[2018-2019]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-2019

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Firstrand Bank Limited The Assistant Commissioner Of C-53, G-Block, 5 Th Floor, Income-Tax, Tcg Financial Centre, Circle-2(3)(1), Bandra-Kurla Complex, Mumbai Vs. Bandra (East)., Mumbai -400051 (Pan: Aabcf1632P) (Appellant) (Respondent) Present For: Assessee : Shri Paras Savla, Advocate Revenue : Shri Annavaram K, Sr. Dr Date Of Hearing : 14.11.2025 Date Of Pronouncement : 12.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed Pursuant To The Directions Of Ld. Dispute Resolution Panel- 1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2022- 23/1043517868(1), Dated 22.06.2022, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Annavaram K, Sr. DR
Section 144C(5)Section 40Section 9(1)(vi)

commission rate as follows: Bank Name Rate State Bank of India 2.30% HDFC 1.80% Average 2.05% 10.2. Ld. TPO thus, applied the external CUP method for benchmarking by adopting the average bank guarantee fee rate charged by third-party banks of 2.05%. After allowing a downward adjustment

Australia and New Zealand Banking Group Ltd., Mumbai vs. DCIT (It)-1(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 7487/MUM/2018[2014-15]Status: DisposedITAT Mumbai12 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2014-15 Australia & New Zealand Deputy Commissioner Of Banking Group Ltd. Income-Tax – 1(1)(2), Unit A, Sixth Floor, Mumbai Cnergy Centre, Appasaheb Marathe Marg, Vs. Prabhadevi, Mumbai – 400 025 (Pan : Aaica3008P) (Appellant) (Respondent) Present For: Assessee : Shri Madhur Agrawal, Advocate Revenue : Shri Annavaram K., Sr. Dr Date Of Hearing : 14.11.2025 Date Of Pronouncement : 12.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed Pursuant To The Directions Of The Dispute Resolution Panel-1, Mumbai, (Drp) Vide Order Dated 04.09.2018 U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground 1: Determination Of The Arm'S Length Price (Alp) Of The International Transaction Relating To Processing Fees Received On Account Of Guarantees Issued To Indian Companies Based On Counter-Guarantee From Overseas Branches

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Annavaram K., Sr. DR
Section 133(6)Section 144C(5)Section 92C

overseas associated enterprises (AE's)]. Ground 2: Rejecting the Transactional Net Margin Method (TNMM) used by the Appellant and adopting External Comparable Uncontrolled Price (CUP) method as the most appropriate method On the facts and in the circumstances of the case and in law, the learned AO. based ... instructions and counter guarantee received from the AE, without undertaking risk on the overseas third party requesting the guarantee. b) In adopting external CUP method as the most appropriate method to determine the ALP of the international transaction, by using information received/collected from third party Indian banks under section

Osg (India) Private Limited, Gurgaon vs. DCIT, Circle-3(1), Gurgaon

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

ITA 4925/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)Section 144B

exist fully in the case. The arm's length price of these alleged services is held to be Rs. Nil on application of CUP method as no independent enterprise would have paid any amount for services where services have not been provided and there is no demonstrable benefits. The assessing ... Pricing documentation. 5. The Learned AO/Hon'ble DRP failed to provide any evidence of the comparable Uncontrolled transactions relied upon for application of the CUP method. In determining the ALP of management fees payment at NIL, the learned AO and the learned CIT(A) have erred in not undertaking

Compass India Support Services Private Limited, Gurgaon vs. DCIT, Circle-4(2), Delhi

ITA 511/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)

furnished by 18.12.2020, along with contemporaneous documentary evidence, the arm's length pricing for these intragroup services would be treated as Nil by applying CUP method.” 2.4 In response, the assessee submitted its reply vide letter dated 13.01.2021, wherein it submitted that during AY 2017-18, the assessee had received ... benchmarked at 'NIL. 2.10 Accordingly, the arm's length price of these intra group services was held to be Rs. Nil on application of CUP method as the TPO observed that no uncontrolled enterprise would have paid any such amount for services and the arm's length price

Compass India Support Services Private Ltd., Gurgaon vs. DCIT, Circle-4(2), Delhi

ITA 1383/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)

furnished by 18.12.2020, along with contemporaneous documentary evidence, the arm's length pricing for these intragroup services would be treated as Nil by applying CUP method.” 2.4 In response, the assessee submitted its reply vide letter dated 13.01.2021, wherein it submitted that during AY 2017-18, the assessee had received ... benchmarked at 'NIL. 2.10 Accordingly, the arm's length price of these intra group services was held to be Rs. Nil on application of CUP method as the TPO observed that no uncontrolled enterprise would have paid any such amount for services and the arm's length price

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

In the result, appeal of the

ITA 5143/MUM/2024[2016]Status: DisposedITAT Mumbai30 Jan 2026

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 254Section 80Section 801ASection 80A(6)

computation of ALP. Whereas, Rule 10B prescribes the mode and manner of computation of ALP under different methods. Undisputedly, the assessee has applied CUP method to determine the ALP. According to the TPO, the assessee, being a power generating company, the cost at which the distribution company supplies power ... regulated tariffs. However, we accept that there is a sufficient degree of similarity between the transaction for reasonably determining the ALP by using the CUP method. 40. Though, Hon'ble Delhi High Court acknowledged the fact that the tariff charged by distribution companies are regulated, however, the Hon'ble High

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

In the result, appeal of the

ITA 5142/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Jan 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 254Section 80Section 801ASection 80A(6)

computation of ALP. Whereas, Rule 10B prescribes the mode and manner of computation of ALP under different methods. Undisputedly, the assessee has applied CUP method to determine the ALP. According to the TPO, the assessee, being a power generating company, the cost at which the distribution company supplies power ... regulated tariffs. However, we accept that there is a sufficient degree of similarity between the transaction for reasonably determining the ALP by using the CUP method. - 40. Though, Hon'ble Delhi High Court acknowledged the fact that the tariff charged by distribution companies are regulated, however, the Hon'ble High

DCIT(CC)-8(3), Mumbai vs. Shapoorji Palloni and Company Private Limited, Mumbai

Appeal of the assessee is allowed and grounds of appeal of Revenue are dismissed”

ITA 1217/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14
Section 143(3)Section 144C(3)Section 92Section 92B

consideration for performance guarantee given by ICICI Bank to the construction parties of Shapoorji Pallonji Mid-East. The TPO has applied Comparable Uncontrolled Price (CUP) method using information called from various banks u/s 133(6) of the Act since there was no internal CUP available. Thereafter, considering the decision ... also submitted that since there was no internal CUP available in the case of the assessee, therefore, the TPO has rightly applied external CUP method to determine the commission for the bank guarantee extended by the assessee for the purpose of associated enterprises. 17. Heard both the sides and perused

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

ITA 1211/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13
For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH, ACCOUNTANT MEMBER ITA No.1150/MUM/2025

Shapoorji Pallonji and Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle -3(3)(1), Mumbai

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

consideration for performance guarantee given by ICICI Bank to the construction parties of Shapoorji Pallonji Mid-East. The TPO has applied Comparable Uncontrolled Price (CUP) method using information called from various banks u/s 133(6) of the Act since there was no internal CUP available. Thereafter, considering the decision ... also submitted that since there was no internal CUP available in the case of the assessee, therefore, the TPO has rightly applied external CUP method to determine the commission for the bank guarantee extended by the assessee for the purpose of associated enterprises. 17. Heard both the sides and perused

Shapoorji Pallonji and Company Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 8(3), Mumbai

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

consideration for performance guarantee given by ICICI Bank to the construction parties of Shapoorji Pallonji Mid-East. The TPO has applied Comparable Uncontrolled Price (CUP) method using information called from various banks u/s 133(6) of the Act since there was no internal CUP available. Thereafter, considering the decision ... also submitted that since there was no internal CUP available in the case of the assessee, therefore, the TPO has rightly applied external CUP method to determine the commission for the bank guarantee extended by the assessee for the purpose of associated enterprises. 17. Heard both the sides and perused

Kadimi Special Steels Private Limited(Amalgamated With Kadimi Tool Manufacturing Company Private Limited), Delhi vs. ACIT, Circle-13(1), Delhi

In the result, Appeals of the Assessee are allowed

ITA 2246/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 143(3)Section 144BSection 144C(3)

contravention to the provisions of Rule 10B(3) of the Rules, since the appellant was in its second full year of operations Application of CUP Method based on Customs price database 8. That without prejudice to Ground No. 3 to 6, the Ld. AO of NaFAC ... circumstances of the appellant's case while benchmarking the international transaction of Purchase of Steel Wire Rods/Wires: a in disregarding the Comparable Uncontrolled Price ('CUP') Method, being a price-based and direct method, alternatively applied by the appellant, as the most appropriate method based on Customs price database instead

Kadimi Special Steels Private Limited(Amalgamated With Kadimi Tool Manufacturing Company Private Limited), New Delhi vs. ACIT, Circle-13(1), Delhi

In the result, Appeals of the Assessee are allowed

ITA 2245/DEL/2022[2017-18]Status: DisposedITAT Delhi23 Jan 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 143(3)Section 144BSection 144C(3)

contravention to the provisions of Rule 10B(3) of the Rules, since the appellant was in its second full year of operations Application of CUP Method based on Customs price database 8. That without prejudice to Ground No. 3 to 6, the Ld. AO of NaFAC ... circumstances of the appellant's case while benchmarking the international transaction of Purchase of Steel Wire Rods/Wires: a in disregarding the Comparable Uncontrolled Price ('CUP') Method, being a price-based and direct method, alternatively applied by the appellant, as the most appropriate method based on Customs price database instead

Assisstant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R

Assisstant Commissioner of Income Corporate Circle 1-1, Chennai vs. Fl Smidth Private Limited, Kanchipuram

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short "Ld.Cit(A)") Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The 'Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

आयकर अपीलीय अधिकरण, 'डी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Assisstant Commisioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

आयकर अपीलीय अधिकरण, 'डी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'D' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Assistant Commissioner of Income Tax, Corporate Circle1(1), Chennai vs. M S. Joyson Anand Abhishek Saftey Systems Pvt Ltd, Kancheepuram

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

ITA 2121/CHNY/2024[2009-10]Status: DisposedITAT Chennai16 Jan 2026AY 2009-10

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Vikram VijayaraghavanFor Respondent: Mr. Krishna Murthy AT, JCIT

assessee, passed a speaking order granting partial relief as under: :: 3 :: & CO No.1/Chny/2025 M/s. M.S. Joyson Anand Abhishek- Safety Systems Pvt. Ltd. 1. CUP Method was accepted for benchmarking import of raw materials only to the extent of transactions supported by adequate documentation, amounting to approximately Rs.3.75 crores ... Tribunal. The assessee has filed cross objections supporting the order of the CIT(A). 6. The Revenue has primarily challenged the acceptance of CUP method by the CIT(A) without adequate substantiation. Revenue further alleged violation of Rule 46A for accepting fresh submissions without calling for a remand report.Allowance

The India Cements Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

The appeal of the assessee is allowed

ITA 2663/CHNY/2025[2021-22]Status: DisposedITAT Chennai13 Jan 2026AY 2021-22

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2663/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

For Respondent: Mr. Shiva Srinivas, CIT
Section 139(1)Section 143Section 250Section 43BSection 80Section 80I

computation towards captive power supply by the thermal power supply plants (unit eligible for deduction u/s.80IA) to the cement units (non-eligible unit) using CUP method by bench marking the rate at which the power is purchased by the captive unit from the Government Electricity Board (DISCOM). The details