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Transfer PricingSection 92CSection 92C2,208 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

assessee is in relation to transfer pricing adjustment on sale of hybrid seeds to AEs. The assessee has benchmarked the transactions by using TNMM as most appropriate method with its Profit lever indicator (PLI) [operating profits / operating cost] at 8.50%. The TPO has rejected the approach of the assessee ... Considered the rival submissions and perused the material available on record. In the instant case, the assessee while computing the ALP, followed the TNMM with OP/OC as most appropriate method for ascertaining the ALP of sale of Hybrid seeds and the margin was shown at 8.50 %. It is relevant

KANDIVALI DATTANI GRAM NO.3 CO-OP. HSG. SOC. LTD,KANDIVALI WEST vs. INCOME TAX OFFICER 42(1)(3), KAUTILYA BHAVAN, MUMBAI

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

ITA 534/MUM/2026[2014-15]Status: DisposedITAT Mumbai17 Mar 2026AY 2014-15

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2014-15 Kandivali Dattani Gram No.3 Income Tax Officer-42(1)(3), Co-Op. Hsg. Soc. Ltd., Kautilya Bhavan, Hemu Kalani Cross Road No.3, Vs. G Block, Kandivali West, Bandra Kurla Complex, Mumbai-400067. Bandra East, Pan : Arkps1535K Mumbai-400051. (Appellant) (Respondent)

For Appellant: Shri Karan VakhariaFor Respondent: Shri Aditya Rai
Section 143(1)Section 154Section 80P

pronounced in the open court on 17-03-2026 [MS. KAVITHA RAJAGOPAL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 17-03-2026 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

KAMINI VELMURUGAN,MUMBAI vs. INCOME TAX OFFICER, MUMBAI

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

ITA 478/MUM/2026[2016-17]Status: DisposedITAT Mumbai17 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2016-17 Kamini Velmurugan, Income Tax Officer, 18/369, Rajeshwari Chs, Ward-42(2)(3), Subhasnagar, Vs. Kautilya Bhavan, Mumbai-400071. Mumbai-400051. Pan : Agzpn9256A (Appellant) (Respondent) For Assessee : Ms. Sailee Gujarathi For Revenue : Shri Aditya Rai, Sr.Dr Date Of Hearing : 04-03-2026 Date Of Pronouncement : 17-03-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 19-11-2025, Pertaining To Assessment Year (Ay) 2016-17. 2. Briefly, The Facts Of The Case Are That The Assessment In This Case Was Completed U/S. 147 R.W.S. 144 R.W.S. 144B Of The Income Tax Act, 1961 („The Act‟), Vide Order Dt. 12-12-2023, Wherein The Ao Has Brought To Tax A Sum Of Rs. 42,50,000/- As Short Term Capital Gains U/S. 45 Of The Act In Absence Of Any Explanation/Evidences Submitted By The Assessee In Respect Of Sale Of Immoveable Property As Well As Cost Of Acquisition. The 2 Assessee Thereafter Carried The Matter In Appeal Before The Ld.Cit(A), Who Has Since Dismissed The Appeal On Account Of Delayed Filing & Against The Said Order, The Assessee Is In Appeal Before Us.

For Appellant: Ms. Sailee GujarathiFor Respondent: Shri Aditya Rai, Sr.DR
Section 147Section 45Section 45(1)

pronounced in the open court on 17-03-2026. [MS. KAVITHA RAJAGOPAL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 17-03-2026 TNMM 5 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

SANJAY SHAMRAO SAWANT,NAVI MUMBAI vs. INCOME TAX OFFICER, WARD 42(3)(3), MUMBAI

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

ITA 469/MUM/2026[2016-17]Status: DisposedITAT Mumbai17 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2016-17 Sanjay Shamrao Sawant, Income Tax Officer, Flat No. B-3/701, 7Th Floor, Ward-35(3)(1), [Presently – Ito, Ward-42(3)(3)] Millenium Towers, Vs. Mumbai. Near Ryan School, Sector-9, Sanpada, Navi Mumbai-400705. Pan : Bdyps3261H (Appellant) (Respondent) For Assessee : None For Revenue : Shri Aditya Rai, Sr.Dr Date Of Hearing : 04-03-2026 Date Of Pronouncement : 17-03-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Addl/Jcit(A)-Kochi [„Ld.Cit(A)‟], Dated 18-09-2025, Pertaining To Assessment Year (Ay) 2016-17. 2. None Appeared On Behalf Of The Assessee Nor Was Any Adjournment Application Filed. However, Considering The Matter, We Find That No Useful Purpose Would Be Served In Adjourning The Matter Any Further & To Decide The Matter Based On Material Available On Record.

For Appellant: NONEFor Respondent: Shri Aditya Rai, Sr.DR
Section 143(3)Section 69Section 69A

pronounced in the open court on 17-03-2026 [MS. KAVITHA RAJAGOPAL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 17-03-2026 TNMM 4 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

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

assessee. 6. In the 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 ... addition of Rs. 50,64,220/-. It is observed from records that the Transfer Pricing Officer (TPO) had adopted Transactional Net Margin Method (TNMM) in respect of the concerned transactions. The TPO had proposed downward adjustment of Rs. 1,45,08,356/-and the same amount was added back

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

assessee. 6. In the 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 ... addition of Rs. 50,64,220/-. It is observed from records that the Transfer Pricing Officer (TPO) had adopted Transactional Net Margin Method (TNMM) in respect of the concerned transactions. The TPO had proposed downward adjustment of Rs. 1,45,08,356/-and the same amount was added back

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)

revenue from IT enabled services. The TPO further held that Bizsense is passing all other filters and that strict comparability is not mandated under TNMM. We further notice that the DRP while considering the objections of the assessee with regard to the above comparable has held that: “2. Bizense Solutions

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

services and\nMarketing and 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 ... buyer and seller and therefore\ncomparability and the guidance note on transfer pricing issued by ICAI in\npara 5.50 which states under TNMM where margins are to be compared,\nthe margin of a 1,000 crore company cannot be compared with that of a\n10 crore company. The two most

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

export to these two AEs. For the purpose of benchmarking, assessee had taken AE as tested party and selected Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) to benchmark the transaction by taking OP/Sales as Profit Level Indicator (PLI). Ld. TPO rejected assessee’s stand of taking

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

export to these two AEs. For the purpose of benchmarking, assessee had taken AE as tested party and selected Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) to benchmark the transaction by taking OP/Sales as Profit Level Indicator (PLI). Ld. TPO rejected assessee’s stand of taking

DY.COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 143(3)

appreciating the selection of functionally similar comparables as that of the assessee and making the adjustment by the ld.TPO, based on the TNMM Method." 2. a) "Whether on the fact and circumstances of the case and in law, the ld. CIT(A) is erred by relying on the stand

GIRGAON VIJAYSHREE CO OPERATIVE HOUSING SOCIETY LIMITED ,MUMBAI vs. ITO WARD 19(1)(1), MUMBAI

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

ITA 457/MUM/2026[2021-22]Status: DisposedITAT Mumbai09 Mar 2026AY 2021-22
For Appellant: NONEFor Respondent: Shri Aditya Rai, Sr.DR
Section 143(1)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

{ "clean_text": "ITA No. 457/Mum/2026\n\nIN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI “J-SMC” BENCH: MUMBAI\n\nBEFORE SHRI

MRS. PARNAL NISHANT MEHAR,MUMBAI vs. ITO WARD 42(3)(1), MUMBAI

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

ITA 8389/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Mar 2026AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Chetan JaiswalFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 147Section 148Section 249(4)

pronounced in the open court on 09-03-2026 [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 09-03-2026 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

PARNAL NISHANT MEHAR,MAHARASHTRA vs. AO WARD 42(3)(1) , MUMBAI, KAUTILYA BHAWAN

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

ITA 8264/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Mar 2026AY 2016-17
For Appellant: Shri Chetan JaiswalFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 147Section 148Section 249(4)

{"clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI “C” BENCH : MUMBAI\nBEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER\nAND

GRANT ROAD (W) OMKAR CO-OPERATIVE HOUSING SOC LIMITED,MUMBAI vs. ITO 19(1)(1), MUMBAI

In the result, this appeal of the assessee is allowed

ITA 260/MUM/2026[2021-22]Status: DisposedITAT Mumbai05 Mar 2026AY 2021-22
For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

{"clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nMUMBAI “H-SMC” BENCH: MUMBAI\nBEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER

GRANT ROAD (W) OMKAR CO-OPERATIVE HOUSING SOC LIMITED,MUMBAI vs. ITO 19(1)(1), MUMBAI

In the result, this appeal of the assessee is allowed

ITA 259/MUM/2026[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

pronounced in the open court on 05-03-2026 [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 05-03-2026 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

NOWROSJEE WADIA AND SONS LTD (SUCESSOR TO SUNFLOWER INVESTMENT AND TEXTILES PVT LTD ),MUMBAI vs. ITO WARD 2(3)(2), MUMBAI

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

ITA 189/MUM/2026[2014-15]Status: DisposedITAT Mumbai05 Mar 2026AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2014-15 Nowrosjee Wadia & Sons Ltd., Ito, Ward-2(3)(2), (Being Successor To Sunflower Mumbai. Investments & Textiles Pvt. Ltd), Vs. 4Th Floor, Neville House, J.N. Heredia Marg, Balard Estate, Mumbai-400001. Pan : Aaacn1836A (Appellant) (Respondent) For Assessee : Shri Chaitanya Joshi For Revenue : Shri Pravin Salunkhe, Sr.Dr Date Of Hearing : 19-02-2026 Date Of Pronouncement : 05-03-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Chaitanya JoshiFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 10(34)Section 143(2)Section 14A

pronounced in the open court on 05-03-2026 [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 05-03-2026 TNMM 6 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

CANCARE RESEARCH FOUNDATION,DADAR WEST vs. COMMISSIONER OF INCOME TAX EXEMPTIONS MUMBAI , CUMBALLA HILL MUMBAI

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

ITA 8426/MUM/2025[2024-25]Status: DisposedITAT Mumbai05 Mar 2026AY 2024-25

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2024-25 Cancare Research Foundation, Commissioner Of Income Tax 25, Moti Bhuvan, (Exemptions), Dr. D‟Silva Road, Vs. Room No. 601, 6Th Floor, Dadar West, Cumballa Hill, Mumbai-400028. Mtnl Te Building, Pedder Road, Pan : Aabtc5371K Dr.Gopalrao Deshmukh Marg, Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Ms. Shivali Mhatre For Revenue : Shri Virabhadra Mahajan, Sr.Dr Date Of Hearing : 25-02-2026 Date Of Pronouncement : 05-03-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Ms. Shivali MhatreFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 80G

pronounced in the open Court on 05-03-2026 [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 05-03-2026 TNMM 4 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

THE OMNISCIENT SECURTIES PVT LTD ,MUMBAI vs. ITO WARD 4(2)(1), MUMBAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 8023/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Kiran MehtaFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 147Section 271ASection 69ASection 69C

pronounced in the open court on 05-03-2026. [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 05-03-2026 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

THE OMNISCIENT SECURITIES PVT LTD,MUMBAI vs. ITO WARD 4(3)(1), MUMBAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 8021/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Kiran MehtaFor Respondent: Shri Virabhadra Mahajan, Sr.DR
Section 147Section 271ASection 69ASection 69C

pronounced in the open court on 05-03-2026. [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 05-03-2026 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

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