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“cost plus method”

Transfer PricingSection 92CSection 92C204 judgments

SHREE NATH KRIPA FOODS PRIVATE LIMITED,RIICO INDUSTRIAL AREA, NOKHA vs. INCOME TAX OFFICER, ITO, WARD, NOKHA

In the result, the appeal is allowed for the statistical purpose

ITA 198/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Feb 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Bleshree Nath Kripa Foods Pvt. Ltd. Income Tax Officer, Ito, Ward F-41 & F-42, Riico Industrial Bikaner Area, Nokha, Bikaner - 334803 Pan No. Aamcs 9124 Q Assessee By Shri Amit Kothari, Ca (Physical) Revenue By Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 30.01.2024 With Respect To Assessment Year 2016-17 Challenging Therein The Order Passed By The Ld. Cit(A) Ex-Parte In Violation Of Principles Of Natural Justice.

Section 143(3)Section 144Section 144cSection 92CSection 92E

report filed by the appellant but also erred by adopting TNMM method for determination of Arms Length Price instead of CUP or cost plus method as adopted by the appellant. 6. Under the facts and circumstances of the case the Ld. AO has grossly erred by making addition

DCIT-13(1)(1), MUMBAI vs. M/S ORACLE FINANCIAL SERVICES SOFTWARE LTD., MUMBAI

In the result, appeal of the revenue stands partly allowed and\nappeal of the assessee stands allowed

ITA 3995/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09
Section 14A

grounds and as the AEs have\nsimply performed marketing agent function for the assessee and it is ideal\nto remunerate them on simple cost plus method being the most appropriate\nmethod under the facts and circumstances, instead of taking assessee\nperforming complex functions as tested party and using the least

ORACLE FINANCIAL SERVICES SOFTWARE LIMITED,MUMBAI vs. ACIT-13(1)(1), MUMBAI

In the result, appeal of the revenue stands partly allowed and\nappeal of the assessee stands allowed

ITA 3432/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09
Section 14A

grounds and as the AEs have\nsimply performed marketing agent function for the assessee and it is ideal\nto remunerate them on simple cost plus method being the most appropriate\nmethod under the facts and circumstances, instead of taking assessee\nperforming complex functions as tested party and using the least

SWATCH GROUP (INDIA) PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(2), C.R. BUILDING

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

ITA 5929/DEL/2024[2021-22]Status: DisposedITAT Delhi14 Jan 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2021-22] Swatch Group (India) Private Deputy Commissioner Of Income Limited, Tax, 4Th Floor, Rectangle-I, Plot No. D- Vs Circle 22(2), 4, Saket District Centre, C.R. Building, I.P. Estate, Delhi, New Delhi-110017. 110002. Pan- Aafcs7516R Assessee Revenue

Section 143(3)Section 92C

interpreted. In order to make comparison studies more accurate, certain adjustments have to be made to the typical MAMs. TPO has used modified cost-plus method, which is also called bright line test or BLT in common parlance, to make comparison more accurate and relevant to the case ... assessee. Despite all the confusion around BLT as a method of calculating arm's length price, BLT is nothing but cost-plus method. it is a statistical tool used for transfer pricing calculations. 3. The basic objective of making this comparability analysis is to determine limit of AMP Expenditure, beyond

DCIT, NEW DELHI vs. M/S. EXXON MOBIL LUBRICANTS PVT. LTD., NEW DELHI

In the result, appeal of the Revenue is party allowed

ITA 1348/DEL/2012[2005-06]Status: DisposedITAT Delhi07 Jan 2026AY 2005-06
Section 143(2)Section 143(3)Section 250(6)Section 92C

selected in earlier as well as subsequent AYs have been tabulated as\nbelow:\nAY\nMethod selected\nTP study\nSupplementary\nsubmission\nTPO\n2004-05 Cost plus method Comparable\nAccepted CUP in\n(\"CPM\")\nuncontrolled Price\nsecond round\nof\nmethod (“CUP”)\nproceedings (refer page\n42-43 of PB Vol.4)\n2005 ... selected in earlier as well as subsequent AYs\nhave been tabulated as below:\nAY\nTP study\nMethod selected\nSupplementary\nsubmission\nΤΡΟ\n2004-05 Cost plus method Resale price method\nAccepted CUP in second\n(\"CPM\")\nround of proceedings\n(refer page 43-51 of PB\nVol.4)\n2005-06 | The present

ORACLE SYSTEMS CORPORATION,NEW DELHI vs. DDIT, NEW DELHI

In the result, assessee’s appeals in :

ITA 3313/DEL/2013[2005-06]Status: DisposedITAT Delhi02 Jan 2026AY 2005-06

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

1836/DEL/2009 & 3313/DEL/2013 Oracle Systems Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable

ORACLE SYSTEMS CORPORATION,NEW DELHI vs. ADIT, NEW DELHI

In the result, assessee’s appeals in :

ITA 1836/DEL/2009[2004-05]Status: DisposedITAT Delhi02 Jan 2026AY 2004-05

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

1836/DEL/2009 & 3313/DEL/2013 Oracle Systems Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable

ORACLE SYSTEMS CORPORATION,NEW DELHI vs. ADIT, NEW DELHI

In the result, assessee’s appeals in :

ITA 1835/DEL/2009[2003-04]Status: DisposedITAT Delhi02 Jan 2026AY 2003-04

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

1836/DEL/2009 & 3313/DEL/2013 Oracle Systems Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable

ORACLE SYSTEMS CORPORATION,NEW DELHI vs. ADIT, NEW DELHI

In the result, assessee’s appeals in :

ITA 1834/DEL/2009[2002-03]Status: DisposedITAT Delhi02 Jan 2026AY 2002-03

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

1836/DEL/2009 & 3313/DEL/2013 Oracle Systems Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable

ORACLE SYSTEMS CORPORATION,NEW DELHI vs. ADIT, NEW DELHI

In the result, assessee’s appeals in :

ITA 1833/DEL/2009[2001-02]Status: DisposedITAT Delhi02 Jan 2026AY 2001-02

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

1836/DEL/2009 & 3313/DEL/2013 Oracle Systems Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable

SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

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

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

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

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

adjustment of Rs. 19,44,90,568/- in ALP of power and steam, by application of external CUP method for electricity and cost-plus method for steam, due to the reasons that no power generator is permitted by the “State Electricity Regulatory authority” to supply directly to consumers, except ... power. 4. That the Dispute Resolution Panel (DRP) has erred in shifting the method from the Transactional Net Margin Method (TNMM) to the Cost Plus Method in the case of steam, and to the External Comparable Uncontrolled Price (CUP) method in the case of electricity, without considering the fact that

R.A.K CERAMICS INDIA PRIVATE LIMITED,SAMALKOT vs. DCIT CIRCLE -3(1), HYDERABAD

In the result, the appeal of the assessee is allowed in\nterms of our aforesaid observations

ITA 465/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19
Section 143(3)Section 144B

facts and circumstances of the case and in law, the Ld. AO/Ld. TPO / Hon'ble Panel\nerred in:\na.\nrejecting Cost Plus Method ('CPM') as the most appropriate method and disregarding\n'mark-up on direct cost' (Gross Profit / Direct and Indirect cost of Production ('GP/DICOP'))\nas an appropriate

DCIT CIRCLE 3 3 1, MUMBAI vs. XORIANT SOLUTIONS PRIVATE LIMITED, MUMBAI

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

ITA 3676/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Pankaj R. Toprani and Ms. Krupa Shah, AdvocatesFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)

include the comparables selected by the assessee without appreciating that the TPO has clearly stated that assessee has not applied the Cost Plus Method as per the provisions of Rule 92C r.w.r. 108? The Ld. CIT(A) failed to appreciate that the comparables selected under CPM by the assessee cannot ... include the comparables selected by the assessee without appreciating that the TPO has clearly stated that assessee has not applied the Cost Plus Method as per the provisions of Rule 920 r.w.r 108? The Ld. CIT(A) failed to appreciate that the comparables selected under CPM by the assessee cannot

DCIT CIRCLE 3 3 1, MUMBAI vs. XORIANT SOLUTIONS PRIVATE LIMITED, MUMBAI

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

ITA 3673/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Pankaj R. Toprani and Ms. Krupa Shah, AdvocatesFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)

include the comparables selected by the assessee without appreciating that the TPO has clearly stated that assessee has not applied the Cost Plus Method as per the provisions of Rule 92C r.w.r. 108? The Ld. CIT(A) failed to appreciate that the comparables selected under CPM by the assessee cannot ... include the comparables selected by the assessee without appreciating that the TPO has clearly stated that assessee has not applied the Cost Plus Method as per the provisions of Rule 920 r.w.r 108? The Ld. CIT(A) failed to appreciate that the comparables selected under CPM by the assessee cannot

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

In the result, the appeal of the revenue in ITA No

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm's length price. The said approach is not mandated and stipulated in the Act or the Rules ... considerable tax literature and text that CUP Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied to a transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods

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