“FAR analysis”

ACIT, CIRCLE-6(1)(2), MUMBAI, MUMBAI vs. ASR MULTIMETALS PVT. LTD., MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Shri Pawan Singh & Shri Girish Agrawal(Hybrid Hearing) Assistant Commissioner Of Asr Multimetals Pvt. Ltd. Income Tax 6(1)(2), Mumbai Vs 202, Steel Center, Iron Market, Room No. 506, 5Th Floor, Mumbai – 400009. Aayakar Bhavan, M. K. Road, Mumbai – 400020. [Pan No. Aaeca9439L] Appellant / Revenue Respondent / Assessee Assessee By Shri Sunil Talathi, Ca (Virtually Present) Revenue By Shri Bhagirath Ramawat (Sr. Dr) Date Of Hearing 11.03.2026 Date Of Pronouncement 11.03.2026

using the rates at which state power distribution companies had purchased power from the generating companies which is appropriate comparable as per FAR analysis. 2. Whether on the fact and circumstances of the case and in law, the Ld. CIT(A) is justified in allowing the assessee for selecting power ... power generating company as tested party for benchmarking of Specified Domestic Transactions of inter unit transfer of power ignoring the comparability factor and FAR analysis. 3. The Appellant prays that the order of the CIT(A) on the above grounds be set aside and that of the Assessing Officer

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

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

charged by the TPO without\nappreciating the facts and circumstances of the case and analyzing the\nsame on the basis of FAR analysis?\n3.2 Whether on the facts and circumstances of the case and in law, the Ld.\nCIT(A) is correct in not upholding the decision ... data\nis available. In selecting the tested party, regard must be had to the\nnature of functions performed, assets employed, and risks assumed\n(FAR analysis). Generally, the entity with a simpler functional profile,\nlimited risks, and no ownership of unique intangibles is chosen as\nthe tested party, since

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

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

charged by the TPO without\nappreciating the facts and circumstances of the case and analyzing the\nsame on the basis of FAR analysis?\n3.2 Whether on the facts and circumstances of the case and in law, the Ld.\nCIT(A) is correct in not upholding the decision ... data\nis available. In selecting the tested party, regard must be had to the\nnature of functions performed, assets employed, and risks assumed\n(FAR analysis). Generally, the entity with a simpler functional profile,\nlimited risks, and no ownership of unique intangibles is chosen as\nthe tested party, since

UNILEVER INDIA EXPORTS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE - 5(2), MUMBAI, MUMBAI

In the result, both the appeals of the assessee for Assessment Years 2015–16 and 2016–17 are allowed

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar & Unilever India Dcit Central Exports Limited, Circle-5(2), Unilever House, B. D. Vs. Room No. 427, 4Th Sawant Marg, Floor, Kautilya Chakala, Andheri Bhawan, C-41 To C- East, Sahar P & T 43, G Block, Bandra Colony, S. O. Kurla Complex, Mumbai-400 099 Bandra (East), Mumbai- 400 051. Pan/Gir No. Aaaci0991D (Applicant) (Respondent) Assessee By Ms. Karishma Phatarphekara/W Shri Harsh Shah & Shri Shreyas Sardesai, Ld. Ars Revenue By Shri Pankaj Kumar, Ld. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 12.02.2026

companies engaged in routine contract manufacturing activity comparable to the assessee‟s AE segment. It was submitted that the assessee had further undertaken detailed FAR analysis and identified contract manufacturers supplying goods to other businesses rather than operating as entrepreneurial entities. 32. The learned AR submitted that the TPOhas rejected

UNILEVER INDIA EXPORTS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE - 5(2), MUMBAI, MUMBAI

companies engaged in\nroutine contract manufacturing activity comparable to the\nassessee's AE segment. It was submitted that the assessee had\nfurther undertaken detailed FAR analysis and identified contract\nmanufacturers supplying goods to other businesses rather than\noperating as entrepreneurial entities.\n32. The learned AR submitted that the TPOhas rejected

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

In the result, the appeal of the assessee bearing

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

between the assessee and the AE, including the assumption that the assessee performs the predominant functions, requires fresh examination after a proper and detailed FAR analysis, supported by documentary evidence and after granting adequate opportunity of being heard to the assessee. In view of the above facts ... provisions, the correct characterization of reimbursements, and the selection of the Most Appropriate Method strictly in accordance with law, after carrying out a fresh FAR analysis and after affording the assessee a reasonable opportunity of being heard. The Ld. AO is also directed to pass a speaking order dealing with

ASIA TODAY LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

In the result, Assessee's appeal is allowed

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)

factors. 3.5.3 The assessee submits that all its activities have been carried out outside India and has also done an FAR analysis to substantiate the same. However, as discussed in preceding paragraphs, it is evident that majority of functions are undertaken in India and further risks are also taken

DCIT(CC)-8(3), MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

entire exercise of ld. TPO is justified, that is, the whole process of determining, who is the tested party, what should be the FAR analysis of the tested party vis-à-vis the comparables under uncontrolled transactions and whether particularly in this case the price charged by the distribution entity