“TNMM”

Transfer PricingSection 92CSection 92C2,208 judgments

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

Leading authorities on TNMM

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.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT

381 ITR 227 · 2016 · High Court

127

citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

SAP Labs India Pvt. Ltd. v. ACIT

44 SOT 156 · 2011 · ITAT

100

citing judgments

Foreign exchange fluctuation gains or losses are operational in nature and must be included in the computation of the operating margin for both the assessee and comparable companies when determining the Arm's Length Price.

DIT (IT) v. Morgan Stanley & Co Inc.

162 Taxmann 165 · 2007 · Supreme Court

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.

Ranbaxy Laboratories Ltd. v. ACIT

68 Taxmann.com 322 · 2016 · High Court

citing judgments

When benchmarking export transactions, the Associated Enterprise (AE) can be considered the tested party if it possesses the least complex functional analysis. The Assessing Officer's acceptance of a methodology in prior years can also support its use.

Trilogy E-Business Software India (P.) Ltd. v. Dy. CIT

29 Taxmann.com 310 · 2013 · ITAT

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.

Capital IQ Information Systems India Pvt. Ltd. v. DCIT

32 Taxmann.com 21 · 2013 · ITAT

citing judgments

A change in depreciation policy impacts an entity's profitability, which is a key factor in assessing its suitability as a comparable company for transfer pricing analysis.

Electronic for Imaging (I) Pvt. Ltd. v. DCIT

85 Taxmann.com 124 · 2017 · ITAT

citing judgments

Comparability of a company for transfer pricing purposes must be decided afresh by the TPO after considering the facts recorded in prior tribunal decisions. The tribunal may direct exclusion of comparable companies based on such prior decisions.

Judgments citing TNMM

Saxon Global India Private Limited, Hyderabad vs. ITO., Ward-3(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1334/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Section 144C(5)Section 92C

During the Transfer Pricing proceedings, the TPO examined the TP documentation and noted that, the assessee had benchmarked its international transactions by applying TNMM as the most appropriate method with OP/OC as the PLI. The TPO, after considering the functional profile and the filters applied by the assessee, rejected

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 491/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.490 & 491/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Dr. Reddy’S Laboratories Limited, Hyderabad. The Acit, Vs. Pin – 500 034. Circle-8(1), Hyderabad – Telangana. 500 084. Pan Aaacd7999Q (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Padamchand Khincha राज" व "ारा /Revenue By: Ms. U Mini Chandran, Cit-Dr

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR

Section 143(3)Section 144C(5)Section 92C

Length Price ("ALP") in respect of Marketing support services paid to M/s 000 Dr. Reddy's Laboratories Limited, Russia, by i. Rejecting the TNMM as most appropriate method and aggregation approach adopted by the Appellant. ii. violating the provisions contained in the Rules; iii. Erred in disregarding the market dynamics ... determination of Arm's Length Price ("ALP"):- in respect of mark-up on R&D charges paid by Appellant by :- i. Rejecting the TNMM as most appropriate method and aggregation approach adopted by the Appellant. ii. violating the provisions contained in the Rules. iii. Incorrectly concluding that benefits have

Dr. Reddys, Laboratories Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 490/HYD/2022[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

For Appellant: CA Padamchand KhinchaFor Respondent: MS. U Mini Chandran, CIT-DR

Section 143(3)Section 144C(5)Section 92C

R.A.K Ceramics India Private Limited, Samalkot vs. DCIT Circle -3(1), Hyderabad

ITA 465/HYD/2022[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Section 143(3)Section 144BSection 144C(5)

Production ('GP/DICOP')) as an appropriate PLI to evaluate the arm's length price. profit level indicator ('PLI'); and adopting Transactional Net Margin Method ('TNMM') as the most appropriate method and return on total costs as an appropriate PLI to evaluate the arm's length price of manufacturing segment ... Study. d. Disregarding the commercial / business rationale justifying the payment; e. the fact that the payment of royalty is forming part of TNMM analysis undertaken by the Ld. TPO and adjusting the payment of royalty separately will lead to double whammy to the Assessee. The Appellant prays that appropriate relief

Dosjibhai Chellabhai Patel, Mumbai vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 6517/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Dec 2025AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2018-19 Dosjibhai Chellabhai Patel, Commissioner Of Income Tax 2/201, Surbhi Apartment, (Appeals), Dafatry Road, Vs. Nfac, Delhi Malad East, Mumbai-400097. Pan : Aadpp5454C (Appellant) (Respondent) For Assessee : Ms. Mansi Joshi For Revenue : Ms. Nidhi Agarwal, Sr.Dr (Virtually Present) Date Of Hearing : 04-12-2025 Date Of Pronouncement : 10-12-2025 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 30-07-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. At The Outset, It Is Noted That There Is A Delay Of 11 Days In Filing The Appeal As Pointed Out By The Registry. After Hearing Both The Parties & Perusing The Material Placed On Record, We Find That There Was Reasonable Cause For The Delay In Filing The Present Appeal & Hence, The Delay Is Hereby Condoned & Appeal Is Admitted For Adjudication.

For Appellant: Ms. Mansi JoshiFor Respondent: Ms. Nidhi Agarwal, Sr.DR

Section 143(2)Section 144Section 50C

statistical purposes. Order pronounced in the open court on 10-12-2025 (JUSTICE (RETD.) C.V. BHADANG) ACCOUNTANT MEMBER Mumbai, Dated: 10-12-2025 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

Radheshyam Shyamlal Gupta, Mumbai vs. Income Tax Officer, WD-11(2)(2), Mumbai

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

ITA 6103/MUM/2025[2012-13]Status: DisposedITAT Mumbai10 Dec 2025AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2012-13 Radheshyam Shyamlal Gupta, Income Tax Officer, 5Th Floor, Ward-11(2)(2), Anuradha Satyamurty Residency Vs. Aayakar Bhavan, Plot No.16, N.S. Road No.11, M.K.Road, Jvpd Scheme, Juhu, Mumbai-400020. Mumbai-400049. Pan : Aabpg4019L (Appellant) (Respondent) For Assessee : Shri Jay Thakkar For Revenue : Shri Brajendra Kumar Date Of Hearing : 02-12-2025 Date Of Pronouncement : 10-12-2025 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 04-07-2025, Pertaining To Assessment Year (Ay) 2012-13. 2. Briefly Stated, Facts Of The Case Are That Assessment In This Case Was Completed U/S. 143(3) R.W.S. 147 Of The Income Tax Act, 1961 („The Act‟), Wherein The Ao Has Determined The Long Term Capital Gain At Rs. 37,21,230/-, Being The 50% Share Of The Assessee In Respect Of Transfer Of 2 Property, Namely, Flat No. 2A & 2B, Anuradha Satyamurty Residency, Plot No.16, 11Th Road, Juhu, Vile Parle (West), Mumbai, Which The Assessee Has Sold Jointly With His Wife, Mrs. Shubhadra R. Gupta. The Assessee Thereafter Carried The Matter In Appeal Before The Ld.Cit(A), Who Has Since Sustained The Order Of The Ao & Dismissed The Appeal Filed By The Assessee On Account Of Delay. Against The Said Order, The Assessee Is In Appeal Before Us.

For Appellant: Shri Jay ThakkarFor Respondent: Shri Brajendra Kumar

Section 143(3)

statistical purposes. Order pronounced in the open court on 10-12-2025. (JUSTICE (RETD.) C.V. BHADANG) ACCOUNTANT MEMBER Mumbai, Dated: 10-12-2025 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

Rajesh Mohan Singh Hajari, Mumbai vs. ITO Ward 16(3)(1), Mumbai

In the result, ground No. 3 of assessee‟s appeal is allowed

ITA 5157/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Dec 2025AY 2014-15

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2014-15 Rajesh Mohan Singh Hajari, Income Tax Officer, Type 4 B/293, Ward-16(3)(1), Dr. Bam Hosp., Vs. Aayakar Bhavan, Byculla, Mumbai-400020. Mumbai-400030. Pan : Aazph4367E (Appellant) (Respondent) For Assessee : Shri Shailesh Bandi For Revenue : Shri Kavan N. Limbasiya, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 10-12-2025 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 21-07-2025, Pertaining To Assessment Year (Ay) 2014-15, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao Of Reopening The Case Under Section 148 Of The It Act, 1961. 2. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao, The Reassessment Order

For Appellant: Shri Shailesh BandiFor Respondent: Shri Kavan N. Limbasiya, Sr.DR

Section 142(1)Section 143(3)Section 147Section 148

partly allowed. Order pronounced in the open court on 10-12-2025 (JUSTICE (RETD.) C.V. BHADANG) ACCOUNTANT MEMBER Mumbai, Dated: 10-12-2025 TNMM 10 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

Pico Deepali Overlays Consortium (by Deepali Designs Exhibits (P.) Ltd.), Delhi vs. DCIT, Central Circle-17, New Delhi

In the result, both the captioned appeals filed by the assessee are allowed

ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

said adjustment is illegal, bad in law and devoid of any merit. ii. That, the AO/TPO/DRP has erred in not accepting the applicability of TNMM and has rejected the same without any basis. The method adopted by the Assessee is correct and the same has been wrongly rejected ... paper books Volume I held that the issues are appearing in order of Ld. DRP regarding TP Report mentions TNMM method while Ld. AO took up the method and held services as nil. In fact, services were provided by PICO Hong Kong. Despite order having been set aside, TPO amended

Pico Deepali Overlays Consortium, Haryana vs. DCIT Central Circle 17, Delhi

In the result, both the captioned appeals filed by the assessee are allowed

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Section 144CSection 153ASection 92C

Massimo Dutti India Private Limited, Gurgaon vs. ACIT, Circle-1(1), Gurgaon

In the result, the appeal of the Assessee is allowed

ITA 2252/DEL/2022[2018-19]Status: DisposedITAT Delhi08 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumarmassimo Dutti India Pvt. Ltd, Vs. Acit, Unit No. 1 (Office 1) 8Th Floor, Circle-1(1), Ambience Island, Nh-8, Gurgaon Gurugram, Hayana-122 002 (Appellant) (Respondent) Pan: Aajcm0103G Assessee By : Shri Ravi Sharma, Adv Ms. Shruti Khimta, Adv Ms. Kashish Gupta, Ca Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144C(5)Section 92C

brand building, promotion, marketing, advertising and creation of intangibles. Accordingly, the Learned TPO Massimo Dutti India Pvt. Ltd applied Transactional Net Margin Method (TNMM) as the MAM and correspondingly substituted the PLI with Operating Profit / Operating Revenue (OP/OR) to ascertain the ALP of the international transaction of import of finished ... Learned TPO, however, accepted the selection of comparables of the Assessee in its Transfer Pricing Study Report (TPSR). The comparables margin using TNMM and the PLI of OP / OR was arrived at 5.79 % and when this was compared with the Assessee‟s operating margin of - 4.35 %, the Learned TPO proposed

M/S Tdk India Private Limited, Kolkata vs. DCIT Circle 11(1), Kolkata, Delhi and Kolkata

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

ITA 2565/KOL/2024[AY 2021-22]Status: DisposedITAT Kolkata05 Dec 2025

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Tdk India Private Limited Dcit, Circle 11(1), Kolkata Wbidc Growth Centre, Kulia Aayakar Bhawan, P-7 Kanchrapara Road, Po Ns Chowringhee Square, Sanatorium,Kalyani, Nadia, Vs. 6Th Floor, Roomno.18, Kolkata-741251, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaaci6950Q Assessee By : Shri Arjit Chakraborthy, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 14.11.2025 Date Of Pronouncement: 05.12.2025

For Appellant: Shri Arjit Chakraborthy, ARFor Respondent: Shri S.B. Chakraborthy, DR

India is remunerated for its marketing efforts on cost plus basis. The Appellant has applied the Transactional Net Margin Method ('TNMM') as the most appropriate method to benchmark the international transaction in provision of marketing support services, selecting TDK India as the tested party and using the Net Cost Plus ... Profit Level Indicator. The TPO rejected the TNMM applied by the appellant simply on the ground that it is an indirect method without finding any flaw in the same. M/s TDK India Private Limited; A.Y. 2021-22 Furthermore, although he stated that data for application of CUP was available

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

service, with its AE. For the purpose of benchmarking, the assessee had aggregated all these transactions as related to its manufacturing activity and used TNMM as the most appropriate method. The assessee worked out its margin from the manufacturing activity at 14.79% and contended that the margins obtained ... observed that the Hon'ble ITAT had not considered the issue regarding aggregation of royalty payment transaction with other transactions. Regarding the contention that TNMM is the most appropriate method for benchmarking the transaction, the TPO observed that either CUP method or 'Other Method' can be considered

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR

Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

service, with its AE. For the purpose of benchmarking, the assessee had aggregated all these transactions as related to its manufacturing activity and used TNMM as the most appropriate method. The assessee worked out its margin from the manufacturing activity at 14.79% and contended that the margins obtained ... observed that the Hon'ble ITAT had not considered the issue regarding aggregation of royalty payment transaction with other transactions. Regarding the contention that TNMM is the most appropriate method for benchmarking _ the transaction, the TPO observed that either CUP method or ‘Other Method' can be considered

Netcracker Technology Solutions (India) Private Limited, Hyderabad vs. DCIT., Circle - 5(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 730/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Dec 2025

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C(3)

3CEB, filed along with the return of income. The A.O. further noted that, the assessee has benchmarked international transactions with its AE by adopting TNMM as the most appropriate method with profit level indicator of OP/OC of 17.45%. Further, the assessee has selected 14 comparables of similar nature with

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14

Section 145Section 92BSection 92C

services and hence have to be aggregated for the purpose of economic analysis. Ought to have appreciated the fact that, the assessee has adopted TNMM method for determining the ALP of its transactions and the operating margin the assessee are much higher than its comparables, hence any adjustment with regard

DCIT, Central Circle-2(3), Mumbai vs. Avinash Construction, Pune

In the result, the appeal of the Revenue is allowed

ITA 4245/MUM/2025[2017]Status: DisposedITAT Mumbai02 Dec 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2017-18 Dcit, Central Circle-2(3), Avinash Construction, Room No. 803, 8Th Floor, Abil House 2, Old Cgo Annexe Building, Vs. Ganesh Khind Road, M.K.Road, Range Hill Corner, Mumbai-400020. Pune-411007. Pan : Aaefa6358H (Appellant) (Respondent)

For Appellant: Shri Vijay MehtaFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR

Section 132Section 153ASection 40A(3)Section 69C

Order pronounced in the open court on 02-12-2025 [ANIKESH BANERJEE] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 02-12-2025 TNMM 19 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

Balaji Powertronics, New Delhi vs. DCIT, Circle- 43(1), New Delhi

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

ITA 2743/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2017-18 M/S. Balaji Powertronics, Vs. Dcit, Circle-43(1), H-56, Udyog Nagar, New Delhi Main Rohtak Road, Delhi – 1100 41 Pan :Aagfb0501M (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 270ASection 80Section 928A

keeping the additions at Rs.21,89,92,804/-. In the present case, even considering the fact the TPO has held that the TNMM method is the most appropriate method and not the CUP method, following adjustment are necessary to make the comparative figures of OP/OR with the comparable

Ubs Business Solutions (India) Private Limited (Successor to Credit Suisse Services (India) Pvt Ltd), Pune vs. PCIT, Pune - 1, Pune, Maharashtra

In the result, appeal of the Assessee is allowed

ITA 1407/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

Section 143(3)Section 144BSection 263Section 80G

this report is tabulated as follows : CS India Whether International Method (Tested party) at arm’s transactions selected Transfer Price Rate / margin length? (INR) TNMM using Provision of software OP/PC as a 7,79,44,49,592 14.90% At ALP development services PLI Provision for TNMM using information technology OP/PC

Mercedes-Benz Research and Development India Private Limited, Bengaluru vs. Assistant Commissioner of Income-Tax, Special Range-4, Bangalore

In the result, appeal of the assessee and the appeal of the revenue are partly allowed

ITA 972/BANG/2023[2017-18]Status: DisposedITAT Bangalore28 Nov 2025AY 2017-18

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2017-18

For Appellant: Sri Kamal Sawhney, A.RFor Respondent: Dr. Diyva K.J., D.R

Section 250Section 92C

budget control o Quality control o Procurement o Strategic management functions o Administrative service function. 4.2 The assessee applied Transaction Net Margin Method (TNMM) as the most appropriate method (MAM) and the Profit Level Indicator (PLI) is considered at Operating Profit by Operating Cost (OP/OC). The operating profit

Income Tax Officer, Mumbai vs. Wasundhara Vinay Joshi, Powai

In the result, the appeal of the Revenue is dismissed

ITA 5907/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Nov 2025AY 2016-17

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2016-17 Income Tax Officer, Wasundhara Vinay Joshi, Room No. 830D, C-111, Sunrise Apts., 8Th Floor, Vs. Raheja Vihar, Kautilya Bhavan, Chandivali Farm Road, Bandra Kurla Complex, Chandivali, Bandra East, Mumbai-400007. Mumbai-400051. Pan : Afjpk0008C (Appellant) (Respondent) For Assessee : Shri Chetan Shinde For Revenue : Shri G.J. Ninawe, Sr.Dr Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 18-08-2025, Pertaining To Assessment Year (Ay) 2016-17, Wherein The Revenue Has Taken The Following Grounds Of Appeal: "1) Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 1,76,860/- U/S 69A Of The Income Tax Act, 1961 Without Considering The Fact That The Assessee Fail To Furnish Demat Account & Copy Of Bank Statement.

For Appellant: Shri Chetan ShindeFor Respondent: Shri G.J. Ninawe, Sr.DR

Section 139Section 147Section 148Section 69A

Revenue is dismissed. Order pronounced in the open court on 28-11-2025 (JUSTICE (RETD.) C.V. BHADANG) ACCOUNTANT MEMBER Mumbai, Dated: 28-11-2025 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