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“profit split method”

Transfer PricingSection 92CSection 92C110 judgments

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

respect of derivative products. Ground 4: Rejecting the Transactional Net Margin Method (TNMM) used by the Appellant and adopting revenue split under Profit Split Method (PSM) method as the most appropriate method On the facts and in the circumstances of the case and in law, the learned AO, based ... remuneration of the India Branch from the said transaction and proposed to make an adjustment of Rs.63,93,140/- using Profit Split Method (PSM) by way of revenue split. Ld. DRP did not find any reason to interfere with the findings of ld. TPO on the said issue

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

other relevant factors as the Board may prescribed namely: - (a)comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method; (e)Transaction net margin method; (f) Any other method provided in Rule 10AB; (g) Further, other methods as per Rule 10AB

CORPORATE WORLDWISE STAY LLP,MUMBAI vs. ACIT CIRCLE -20(1), MUMBAI

In the result, the appeal of the assessee bearing

ITA 5940/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Jan 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

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

subjected to the Transfer Pricing and necessary directions in this regard may please be issued. 3. Objection against application of Profit Split Method by the Transfer Pricing Officer for determination of ALP 3.1 Without any prejudice to any of the earlier Grounds, the DRP has erred in confirming the action ... assessment unit in applying the profit split method as the most appropriate method in the case of the appellant. 3.2 The appellant respectfully submits that on the facts of its case, the profit split method cannot be applied in its case. The action of the assessment unit in 3 Corporate

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)

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 and is applicable 3.2 That on facts and in law the CIT(A) erred in upholding the quantum attributed

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)

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 and is applicable 3.2 That on facts and in law the CIT(A) erred in upholding the quantum attributed

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)

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 and is applicable 3.2 That on facts and in law the CIT(A) erred in upholding the quantum attributed

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)

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 and is applicable 3.2 That on facts and in law the CIT(A) erred in upholding the quantum attributed

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)

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 and is applicable 3.2 That on facts and in law the CIT(A) erred in upholding the quantum attributed

EREVMAX TECHNOLOGIES PVT. LTD.,KOLKATA vs. D.C.I.T./A.C.I.T., TP-1, , KOLKATA

Appeal of the assessee is partly allowed for statistical purposes

ITA 2551/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: Us In The Paper Book)

Section 143(3)

Erevmax Technologies Pvt. Ltd. the assessee bills the AE at a mark-up of 5% on cost. The assessee had followed the Profit Split Method (PSM) of pricing such exports and has disclosed the calculation of receipts on that basis is the Return of Income. However ... worked out an upward adjustment of Rs. 1,76,78,365/- with the following observations: “6.3 The assessee had relied on the Profit Split Method (PSM) and objected on the TNMM method applied by the undersigned as the Most Appropriate Method (MAM) On perusal of details as submitted

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

ITA 8361/DEL/2019[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri S. K,. Jadav, CIT DR
Section 115JSection 143(3)Section 144C(5)Section 92C

computation by applying six methods namely; comparable un-controlled price method (CUP), re-sale price Vodafone Idea Ltd method (RPM), cost method (CPM), profit split method (PSM), transactional net margin method (TNMM) and the residuary one such other methods as may be prescribed by the Central Board of Direct Taxes

TUPPERWARE INDIA PRIVATE LIMITED,CONNAUGHT PLACE NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE THROUGH DEPUTY COMMISSIONER OF INCOME TAX, IP ESTATE NEW DELHI

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

Appellant incurs such expenses on its own account for selling its products in India and derives adequate risks / rewards thereof; 5.7. applying Residual Profit Split Method (‘RPSM’) using Bright Line Test (BLT) approach and by following erroneous, incorrect methodology based on fallacious assumptions and not in accordance with the provision

LEAR AUTOMOTIVE INDIA P. LTD. ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17
For Appellant: \nShri Dhanesh Bafna &For Respondent: \nShri Prakash L. Pathade
Section 143(3)Section 144C(13)Section 144C(5)

nappropriate method to determine the arm's length operating results of\ninternational transaction pertaining to payment of RHQ fees to Lear\nShanghai.\n9.4.3.4. Profit split method\nLear Shanghai does not own any non-routine intangibles and further the\noperations of Lear Shanghai can be independently evaluated. Therefore, the\nPSM

CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC. ,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(2)(1), INTERNATIONAL TAXATION, DELHI

In the result, the assessee’s both appeals are allowed as above

ITA 1892/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Sept 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

ACIT,CIRCLE 1(2)(1), INTERNATIONAL TAXATION, NEW DELHI vs. CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC., USA

In the result, the assessee’s both appeals are allowed as above

ITA 724/DEL/2023[2019-20]Status: DisposedITAT Delhi30 Sept 2025AY 2019-20

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

DCIT, CIRCLE-1(2)(1) INT. TAXATION, NEW DELHI vs. CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC., USA

In the result, the assessee's both appeals are allowed as above

ITA 723/DEL/2023[2018-19]Status: DisposedITAT Delhi30 Sept 2025AY 2018-19
Section 234ASection 270A

restricted the attribution of\nbusiness income @ 8.35% of the profit of CIS assessable in the hands of the\nassessee based on the profit split method. The issue of attribution of profit\nhas been challenged by both parties in this appeal.\n7. The Ld. AO also held Link charges as equipment

CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC.,UNITED STATES vs. ACIT, (INT.TAXATION) 1(2)(1), NEW DELHI

In the result, the assessee’s both appeals are allowed as above

ITA 668/DEL/2023[2019-20]Status: DisposedITAT Delhi30 Sept 2025AY 2019-20

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC. ,UNITED STATES vs. ACIT, (INT.TAXATION) 1(2)(1), NEW DELHI

In the result, the assessee’s both appeals are allowed as above

ITA 667/DEL/2023[2018-19]Status: DisposedITAT Delhi30 Sept 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC.,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION)- 1(2)(1), NEW DELHI

In the result, the assessee’s both appeals are allowed as above

ITA 3512/DEL/2023[2021-22]Status: DisposedITAT Delhi30 Sept 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

ACIT, INTERNATIONAL TAXATION, CIRCLE-1(2)(1), NEW DELHI vs. CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC., UNITED STATE OF AMERICA

In the result, the assessee’s both appeals are allowed as above

ITA 1281/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

CONCENTRIX CVG CUSTOMER MANAGEMENT GROUP INC.,DELHI vs. DCIT CIRCLE-1(2)(1)INTERNATIONAL TAXATION , DELHI

In the result, the assessee’s both appeals are allowed as above

ITA 1086/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.7727/Del/2017, A.Y. 2013-14 Ita No.7924/Del/2018, A.Y. 2014-15 Ita No.1086/Del/2022, A.Y. 2017-18 Ita No.667/Del/2023, A.Y. 2018-19 Ita No.668/Del/2023, A.Y. 2019-20 Ita No.3512/Del/2023, A.Y. 2021-22 Ita No.1892/Del/2025, A.Y. 2022-23 Concentrix Cvg Customer Deputy Commissioner Management Group Inc., (Earlier Of Income Tax, Known As ‘Convergys Customer Vs Circle - 1(2)(1), Management Group Inc.’) International Taxation, C/O Pwc Pvt. Ltd., E-2 Tower, Civic Centre Sucheta Bhawan, Minto Road Gate No. 2, 1St Floor, New Delhi 11-A, Vishnu Digambar Marg, New Delhi Pan: Aaccc8989M (Appellant) (Respondent)

Section 234ASection 270A

restricted the attribution of business income @ 8.35% of the profit of CIS assessable in the hands of the assessee based on the profit split method. The issue of attribution of profit has been challenged by both parties in this appeal. 7. The Ld. AO also held Link charges as equipment

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