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“transactional net margin method”

Transfer PricingSection 92CSection 92C691 judgments

The decision most relied on for transactional net margin method is Rampgreen Solutions Pvt. Ltd. v. CIT (377 ITR 533), cited in 196 judgments on BharatTax.

Leading authorities on transactional net margin method

Rampgreen Solutions Pvt. Ltd. v. CIT
377 ITR 533 · 2015 · High Court
196
citing judgments

Knowledge Process Outsourcing (KPO) service providers are functionally dissimilar to Business Process Outsourcing (BPO) or Information Technology Enabled Services (ITeS) providers and cannot be compared for transfer pricing purposes, even under the Transactional Net Margin Method (TNMM). Further, companies with significantly different business models, such as those with extensive subcontracting, should be excluded as comparables.

DIT (IT) v. Morgan Stanley & Co Inc.
162 Taxmann 165 · 2007 · Supreme Court
90
citing judgments

The profits of a Permanent Establishment (PE) must be determined on the basis of what an independent enterprise would derive, using the Transactional Net Margin Method (TNMM) for profit attribution. When applying TNMM, the operating profit from an international transaction should be compared with the operating profit margin of comparables.

CIT v. Pentair Water India (P.) Ltd.
381 ITR 216 · 2016 · High Court
69
citing judgments

Companies with significantly higher turnover, indicating differing functional and risk profiles, are not comparable for transfer pricing benchmarking. Such large companies must be excluded from the list of comparables when benchmarking against an assessee with a much smaller turnover.

Huawei Technologies India Pvt. Ltd. v. JCIT
101 Taxmann.com 313 · 2019 · ITAT
67
citing judgments

Working capital adjustments are permissible and crucial for comparability analysis when determining the arm's length price of international transactions, especially when an assessee's claim for such adjustment has been denied.

Trilogy E-Business Software India (P.) Ltd. v. Dy. CIT
29 Taxmann.com 310 · 2013 · ITAT
48
citing judgments

For Transfer Pricing, this case clarifies that foreign exchange gains can be considered operating revenue for ITES providers, acknowledges the impact of offshore versus onsite development pricing on margins even when using TNMM, and affirms the use of a turnover filter for selecting comparable companies.

Dresser-Rand India (P.) Ltd. v. Addl. CIT
13 Taxmann.com 82 · 2011 · High Court
43
citing judgments

An Assessing Officer cannot disregard an assessee's decision to avail services from associated enterprises, even if the assessee has internal expertise, as the determination of necessity is the assessee's prerogative. The Transfer Pricing Officer's role is to determine the arm's length price, not the need for the service itself.

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.

Mobis India Ltd. v. Dy. CIT
38 Taxmann.com 231 · 2013 · ITAT
38
citing judgments

A working capital adjustment is unreliable if it is based on broad approximations, estimations, and assumptions, and the assessee fails to demonstrate how the adjustment was arrived at.

Judgments citing transactional net margin method

Fluor Daniel India P.Ltd, New Delhi vs. Addl.CIT, Special Range-3, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 6581/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Apr 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Om Prakash, CIT-DR
Section 143(3)Section 144CSection 271Section 92C

debt free company and therefore, no imputation of interest on account of outstanding receivables is warranted; 3.3. Ignoring the application of Transactional Net Margin Method and the fact that working capital adjustment takes into account the impact of outstanding receivables on profitability and therefore, no further imputation of interest

M/S Lubrizol India Private Limited, Mumbai vs. The Office of the Deputy Commissioner of Income Tax, DCIT/ACIT, Circle-3(4), Mumbai

In the result, the appeals of assessee for both AYs are allowed

ITA 6099/MUM/2024[2021-22]Status: DisposedITAT Mumbai21 Apr 2025AY 2021-22

Bench: Shri Pawan Singh & Shri Girish Agrawal & (Physical Hearing) M/S. Lubrizol India Private Limited Deputy Commissioner Of Plant 9/3, Thane-Belapur Road, Turbhe, Vs Income Tax, Dcit/Acit, Navi Mumbai – 400705. Circle – 3(4), Mumbai. [Pan No. Aaacl 0126 H] Appellant / Assessee Respondent / Revenue Assessee By Shri Paras Savla Advocate A/W Ms. Rajnandini Shukla, Ca/ Ar Revenue By Ms. Neena Jeph, (Cit Dr) / Shri Kiran Unavekar, Sr. Dr Date Of Hearing 27.03.2025 Date Of Pronouncement 21.04.2025 Order Under Section 254(1) Of Income Tax Act

Section 254(1)

read with Rule 100 of the Income-tax Rules, 1962 ("Rules"). 3. Erred in rejecting the application of Transactional Net Margin Method ("TNMM") as the Most Appropriate Method ("MAM") used by the Appellant for benchmarking the international transaction in respect of its exports of chemical additives to its associated enterprise ... Private Limited the TPSR, the assessee reported international transaction with regard to export of chemical additives to its foreign AEs. The assessee adopted Transaction Net Margin Method (TNMM) as the most appropriate method. The TPO entered into reference and rejected the most appropriate method adopted by assessee. The TPO applied

Lubrizol India Private Limited, Mumbai vs. DCIT, Circle-3(4), Mumbai

In the result, the appeals of assessee for both AYs are allowed

ITA 4630/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawal & (Physical Hearing) M/S. Lubrizol India Private Limited Deputy Commissioner Of Plant 9/3, Thane-Belapur Road, Turbhe, Vs Income Tax, Dcit/Acit, Navi Mumbai – 400705. Circle – 3(4), Mumbai. [Pan No. Aaacl 0126 H] Appellant / Assessee Respondent / Revenue Assessee By Shri Paras Savla Advocate A/W Ms. Rajnandini Shukla, Ca/ Ar Revenue By Ms. Neena Jeph, (Cit Dr) / Shri Kiran Unavekar, Sr. Dr Date Of Hearing 27.03.2025 Date Of Pronouncement 21.04.2025 Order Under Section 254(1) Of Income Tax Act

Section 254(1)

read with Rule 100 of the Income-tax Rules, 1962 ("Rules"). 3. Erred in rejecting the application of Transactional Net Margin Method ("TNMM") as the Most Appropriate Method ("MAM") used by the Appellant for benchmarking the international transaction in respect of its exports of chemical additives to its associated enterprise ... Private Limited the TPSR, the assessee reported international transaction with regard to export of chemical additives to its foreign AEs. The assessee adopted Transaction Net Margin Method (TNMM) as the most appropriate method. The TPO entered into reference and rejected the most appropriate method adopted by assessee. The TPO applied

Tupperware India Private Limited, New Delhi vs. DCIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 462/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

drew our attention at page 6 of the pb giving workings thereon. It was also submitted that the assessee had applied Transactional Net Margin Method (TNMM) as the most appropriate method (MAM) for benchmarking the international transaction qua the export of finished goods to its AEs which has been accepted

Tupperware India Private Limited, New Delhi vs. ACIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 2409/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

drew our attention at page 6 of the pb giving workings thereon. It was also submitted that the assessee had applied Transactional Net Margin Method (TNMM) as the most appropriate method (MAM) for benchmarking the international transaction qua the export of finished goods to its AEs which has been accepted

Ariston Group India Private Limited, Pune vs. The Assessement Unit, Income Tax Department, NFAC and the DCIT, Circle 1(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1680/PUN/2024[2020-21]Status: DisposedITAT Pune09 Apr 2025AY 2020-21

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

Section 143(3)Section 144Section 144BSection 144C(13)Section 37(1)Section 92C

directions of the Hon'ble DRP erred in law and on the facts and in circumstances of the case in rejecting Transactional Net Margin Method (TNMM') as most appropriate method and transfer pricing documentation maintained by the Appellant. 2.2 The Ld. AO/TPO pursuant to the directions

Dr. Bhim Rao Ambedkar Mahasang Haryana, Faridabad vs. CIT (Exemptions), Chandigarh/Faridabad

In the result, both the appeals are partly allowed for statistical purposes

ITA 3196/DEL/2023[NA]Status: DisposedITAT Delhi08 Apr 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv. & ShriFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 250Section 92C

length in terms of the provisions of the Act. The Appellant has benchmarked the international transactions pertaining to freight forwarding using. Transactional Net Margin Method ("TNMM") as the most appropriate method with net profit margin ("NPM") on sales (refer pages 461 to 469 of the paper book ... that while the transfer pricing study report mentions CUP as most appropriate method, the related column in the Form 3CEB states that TNMM (Transaction Net Margin Method) is most appropriate method, even as the assessee subsequently clarifies that of CUP. It was explained by the assessee that

L & T Mhi Power Trubine Generators Pvt Ltd (Fromerly Known As L & T Mhps Turbine Generators Pvt Ltd), Mumbai vs. Assistant Comm. of Income Tax Circle 2(2)(1), Mumbai

In the result, the appeal of the assessee is In the result, the appeal of the assessee is dismissed

ITA 2394/MUM/2022[2014-2015]Status: DisposedITAT Mumbai07 Apr 2025AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2014-15 L&T Mhi Power Turbine Generators Asst. Cit Circle 2(2)(1), Pvt. Ltd., Aayakar Bhavan, M.K. Marg, Vs. (Formerly Known As L&T Mhps Mumbai-400001. Turbine Generators Pvt. Ltd.), L&T House, N M Marg, Ballard Estate, Fort, Mumbai-400001. Pan No. Aabcl 2729 F Appellant Respondent

For Respondent: Ms. Puja Choudhary, Virtually

carried out by the company by benchmarking analysis carried out by the company by benchmarking analysis carried out by the company by adopting Transactional Net Margin Method (TNMM) for adopting Transactional Net Margin Method (TNMM) for adopting Transactional Net Margin Method (TNMM) for benchmarking. benchmarking. 2. Without prejudice to Ground

Ras Lifesciences Private Limited, New Delhi vs. DCIT., Circle 3(1), Hyderabad

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

ITA 788/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Apr 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: : Smt. M. Narmada, CIT-DR
Section 143(3)Section 92C(3)

notice on this count which is sine qua non for making an ALP adjustment under transfer pricing regulations; 3.7. Erred in considering the Transactional Net Margin Method (TNMM') as the most appropriate method and adopting operating profit on operating cost ("OP/OC") as the Profit Level Indicator for benchmarking the subject ... determining the Arm’s Length Price (“ALP”). However, the Ld. TPO rejected the method adopted by the assessee and adopted the Transaction Net Margin Method (“TNMM”) as MAM. The Ld. AR further submitted that, the Ld. TPO selected the comparables that do not match with the functions of the assessees

Cvent India Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, the appeals of the assessee in both the A

ITA 187/DEL/2016[2011-12]Status: DisposedITAT Delhi26 Mar 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: ShriDheeraj Kumar Jaiswal, Sr. DR
Section 92CSection 92D

respect of the BPO services. The Assessee has earned a net profit margin of 14.43% on operating expenses.7.The assessee has selected Transactional Net Margin Method ("TNMM") as the most appropriate method and benchmarked the international transactions using operating profit/operating cost ("OP/OC") as the profit level indicator ("PLI").The assessee selected

Gallagher Service Center LLP (Formerly Known As Gallagher Operations Support Services P Ltd), Pune vs. Assistant Commissioner of Income-Tax, NFAC, Delhi

In the result, the Ground Number 6 is Partly Allowed for Statistical purpose

ITA 679/PUN/2022[2018-19]Status: DisposedITAT Pune24 Mar 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.679/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Gallagher Services Center V Additional/Joint Llp, S Commissioner Of Income 401, Delta 2, Gigaspace It Tax. Park, Vimannagar, Pune – 411014. Pan: Aaqfg7417F Appellant/ Assessee Respondent /Revenue Assessee By Shri M.P.Lohia – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 23/01/2025 Date Of Pronouncement 24/03/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Assessment Order Of Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961; Dated 15.07.2022 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, The Appellant Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D)

Section 143(3)Section 144Section 144BSection 253(1)(d)

value of International Transaction of business support service to its AE is Rs.2,31,96,03,040/-. Assessee had benchmarked the transaction using Transactional Net Margin Method(TNMM). The operating profit on operating cost of the assessee was 13.3%. Assessee’s service is in the category of ITES. Ld.AR

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Rule 10A.When section 92C is read along with Rules 10B(e), and 10A, it becomes abundantly clear that in computing ALP under the transactional net margin method, a comparison of the assessee's net profit margin from international transactions with its AEs has necessarily to be made with that