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“advance pricing agreement”

Transfer PricingSection 92CCSection 92CC125 judgments

ELECTRONFAB ENGINEERING PVT LTD,SEEPZ SEZ MUMBAI vs. INCOME TAX OFFICER, MUMBAI

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

ITA 4828/MUM/2025[2024-25]Status: DisposedITAT Mumbai16 Mar 2026AY 2024-25
For Appellant: Shri Nishit Gandhi, Advocate (virtually appear) & Mrs. Usha DalalFor Respondent: Shri Himanshu Joshi (Sr. DR)
Section 115BSection 115JSection 139(5)Section 143(1)Section 250

n119(2)(b), enter unique number /Document Identification Number (DIN) and date of such\nnotice/Order, or if filed u/s 92CD enter date of advance pricing agreement\nUnique number/ Document Identification number (DIN)\nDate of such Notice or Order or if filed u/s 92CD enter\ndate of advance pricing agreement\nResidential

ERICSSON INDIA GLOBAL SERVICES PVT LTD,NEW DELHI vs. ACIT SPL. RANGE 3, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 2367/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Mar 2026AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singhassessment Year : 2013-14

For Appellant: Shri Paras S. Savla, AdvocateFor Respondent: Shri M.S. Nethrapal, CIT-DR
Section 143(1)Section 143(13)Section 143(2)Section 143(3)Section 144C(3)Section 234BSection 234CSection 254(2)Section 92C

erred in levying interest u/s 234B and 234C of the Income-tax Act, 1961 (‘Act’) on the additional income agreed as per the Advance Pricing Agreement entered between the appellant and the Central Board of Direct Taxes and offered to tax by the appellant in the modified return of income ... appeal before the Commissioner of Income Tax (Appeals). During the pendency of appeal before the CIT(A), the assessee entered into an Advanced Pricing Agreement (APA) on 20th March, 2018. Pursuant to the said APA, the assessee filed modified return on 29th June, 2018 declaring total income of Rs.333

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

Addition of INR.3,41,80,42,376/-. 5. The Assessee filed objections before DRP. Vide letter, 14/08/2024, the Assessee placed on record the Advance Pricing Agreement (APA). Since, the Transfer Pricing Addition in relation to IT Segment, ITeS Segment and interest on receivables were coved by the APA, no directions

VODAFONE INDIA SERVICES PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the grounds of

ITA 5888/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jan 2026AY 2022-23

Bench: Shri Pawan Singhshri Girish Agrawal(Physical Hearing) Vodafone India Services Private Dcit Circle-8(3)(1) Mumbai, Aayakar Bhawan, Limited, 201-206, 2Nd Floor, M.K. Road, Mumbai-400020 Shiv Smriti Chambers, Vs 49/A, Anne Besant Road, Above Corporation Bank, Worli, S.O. Mumbai-400018, Maharashtra Pan: Aaacz 1849 D Appellant (Respondent) Assessee Represented By : Shri Ajit Jain Advocate Department Represented By : Shri Pankaj Kumar Cit-Dr Date Of Hearing : 09.12.2025 Date Of Pronouncement Of Order : 30.01.2026

Section 143(3)Section 144CSection 254(1)Section 270Section 271

opted receivable for services(provision of information technology enabled services (ITeS) is Vodafone India Services Private Limited already dealt with in the bilateral advance pricing agreement (BAPA) signed between the Appellant and the CBDT. (3) The AO/NFAC have ignored the mutual agreement signed between the competent authorities of United Kingdom ... invoices have been realised during the period under consideration. The assessee specifically stated that 3 Vodafone India Services Private Limited there is advance pricing agreement (APA) which specifically contained the term that amount should be realised in a manner and weighted average of realisation of invoices is 60 days

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

ITA 466/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2016-17
Section 115Section 143(3)Section 234BSection 92C

revised return on 27-03-2018 declaring total income of Rs.149,22,97,140/-. The assessee company entered into an Advance Pricing Agreement (hereinafter referred as APA) with Central Board of Direct Taxes on 19- 08-2019 under section 92CC of the Act for the Asst. Years ... 466/Ahd/2025 A.Y. 2016-17 Page No 4 Sophos Technologies Pvt. Ltd. vs. DCIT the modified return of income filed pursuant to the Advance Pricing Agreement (APA) It is prayed that the Ld. AO be directed to delete the impugned interest under section 2348 of the Act. 3. Levy of additional

MORGAN STANLEY ADVANTAGE SERVICES PRIVATE LIMITED,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

Appeal is dismissed

ITA 3533/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai08 Dec 2025

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Morgan Stanley Advantage The National Faceless Services Private Limited Assessment Centre Building No. 5, Athena Vs. Delhi Mindspace, Sector 30, Goregaon West, Mumbai-400 064. Pan : Aaeca3400B Appellant Respondent

For Respondent: Assessee by Shri Madhur Agrawal, CA
Section 270ASection 80GSection 92C

Crore. 8. During the hearing before ITAT Ld. AR of appellant has filed a paper book stating that they entered into a Bilateral Advance Pricing Agreement with Central Board of Direct Taxes (CBDT) on 15/03/2024 and computed the income and filed a Modified Return of Income u/s. 92CD

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)

company agreements entered into between the Assessee and its associated enterprises which provide a credit period of 94 days in accordance with the Advance Pricing Agreement signed for previous years. 7 On the facts and circumstances of the case and contrary to law, the addition made by the L.d. AO/Ld

GIA INDIA LABORATORY PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-14(1)(2), MUMBAI

ITA 4395/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Nov 2025AY 2020-21

Bench: Shri Rahul Chaudhary (Jm) & Shri Omkareshwar Chidara (Am) Gia India Laboratory Pvt. Ltd. Dcit, Circle-14(1)(2) 10Th Floor, Trade Centre Room No. 455 Vidyanagari, S.O. Mumbai Vs. Aayakar Bhavan, M.K. 400 098. Road, Mumbai-400 020. Pan : Aaccg9457G Appellant Respondent

For Respondent: Shri J.D. Mistry & Shri
Section 144C(1)Section 244ASection 80GSection 92C

payment of royalty to the total income of the appellant by computing arm’s length price of royalty at 53% as per earlier Advance Pricing Agreement (APA) dated 7.5.2018. Subsequently, the DRP has confirmed this upward adjustment. 4. At the time of hearing before ITAT ... appellant company has stated that the appellant company has signed Unilateral Advance Pricing Agreement with CBDT on 27.3.2025 in terms of payment of Royalty to Associated Enterprises (AE) was a covered transaction. The Ld. AR of the appellant has filed a note before the Bench where relevant extract

BLASER SWISSLUBE SOLUTIONS PVT. LTD.,GURGAON vs. ASSESSMENT UNIT, DELHI

In the result, the appeal of the assessee is dismissed

ITA 5896/DEL/2024[2021-22]Status: DisposedITAT Delhi31 Oct 2025AY 2021-22

Bench: Shri Mahavir Singh & Shri Manish Agarwalblaser Swisslube Solutions Assessment Unit Pvt.Ltd., 1001, 10Th Floor, C.R. Building, Ito Time Tower, Main M.G.Road, Vs. Delhi. Haryana-122002 Pan:Aaicb1062A (Appellant) (Respondent) Assessee By Shri Priyansh Jain, Ca Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 31.10.2025 Date Of Pronouncement 31.10.2025

Section 143(3)Section 144B

undertaking that it will not press Ground No.2, challenging the issue of limitation raised in the appeal memo. 3. Ld.AR further submits that Advance Pricing Agreement (“APA”) have been concluded and signed on 21.02.2025 and all the issues of international transactions i.e. import of finished goods and provision of marketing

DCIT, RANGE-3, LUCKNOW vs. M/S. PRAYAGRAJ POWER GENERATION COMPANY LTD.,, NOIDA

In the result, ground no. 1 of appeal is dismissed and ground no

ITA 393/LKW/2020[2016-17]Status: DisposedITAT Lucknow15 Oct 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115J

book profit of the previous year due to income of past year or years included in the book profit on account of an advance pricing agreement entered into by the assessee under section 92CC or on account of secondary adjustment required to be made under section 92CE, the Assessing Officer

BASF INDIA LIMITED,MUMBAI vs. DCIT CIRCLE 14(1)(1), MUMBAI

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

ITA 2001/MUM/2025[2013-14]Status: DisposedITAT Mumbai15 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 143(3)Section 147Section 250Section 92C

assessee also filed appeal before the Ld. CIT(A) against non grant of credit for taxes paid. The assessee then entered into Advance Pricing Agreement ('APA') with the Central Board of Direct Taxes on 20 July 2023 pursuant to which the underlying transaction in respect of which transfer pricing adjustment

BASF INDIA LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 14(1)(1), MUMBAI

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

ITA 2000/MUM/2025[2013-14]Status: DisposedITAT Mumbai15 Oct 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 143(3)Section 147Section 250Section 92C

assessee also filed appeal before the Ld. CIT(A) against non grant of credit for taxes paid. The assessee then entered into Advance Pricing Agreement ('APA') with the Central Board of Direct Taxes on 20 July 2023 pursuant to which the underlying transaction in respect of which transfer pricing adjustment

ACIT , SPL. RANGE-9, NEW DELHI vs. TIMEX GROUP INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7598/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Sept 2025AY 2013-14

Bench: Shri Vimal Kumar\Nand\Nshri Brajesh Kumar Singh\Nita No.7526/Del/2019\N[Assessment Year: 2013-14]\N\Nm/S Timex Group India Ltd.\N106-107, Ambadeep Building,\Nkasturba Gandhi Marg,\Nnew Delhi-110001\Npan-Aaact0773C\Nassessee\Nvs\Nadditional Commissioner Of Income\Ntax, Special Range-9,\Nnew Delhi-110002\Nrevenue\Nita No.7598/Del/2019\N[Assessment Year: 2013-14]\N\Nadditional Commissioner Of\Nincome Tax, Special Range-9,\Nnew Delhi-110002\Nm/S Timex Group India Ltd.\N106-107, Ambadeep Building,\Nvs Kasturba Gandhi Marg,\Nnew Delhi-110001\Npan-Aaact0773C\Nrevenue\Nassessee\Nassessee By\Nshri Tushar Jarwal, Adv.\Nshri Aayush Nagpal, Adv. &\Nshri Vikrant Maheshwari, Adv.\Nrevenue By\Nshri Rohit Garg, Cit-Dr\Ndate Of Hearing\N01.07.2025\Ndate Of Pronouncement\N26.09.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Are Cross Appeals Filed By The Assessee As Well As By\Nthe Revenue, Against The Order Of The Ld. Commissioner Of\Nincome Tax (Appeals)-44, New Delhi, Dated 28.06.2019 Arising\Nfrom The Assessment Order Dated 07.02.2017 Passed Under\Nsection 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred\Nto As 'The Act') Relating To Assessment Year 2013-14.\N1.

Section 143(3)Section 40Section 92Section 92BSection 92C

outset, the Ld. AR referring to its letter dated\n02.04.2025 placed before us submitted that the assessee has\nentered into unilateral Advance Pricing Agreement (APA) under\nSection 92CC of the Act, (hereinafter referred to as the 'Act')\ndated 29.11.2019 relating to AMP expenses subject matter of\ndispute in the department ... department's appeal does not\nsurvive, as it relates only to TP issues. It was further\nsubmitted that a true copy of the advance pricing agreement\ndated 29.11.2019 was also annexed with the said letter. Based\non the said agreement and the ITAT's order sheet noting dated\n01.10.2024

TIMEX GROUP INDIA LTD.,NEW DELHI vs. ADDI. CIT SPL.RANGE-9, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7526/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Sept 2025AY 2013-14

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Timex Group India Ltd. Additional Commissioner Of Income 106-107, Ambadeep Building, Tax, Special Range-9, Kasturba Gandhi Marg, Vs New Delhi-110002 New Delhi-110001 Pan-Aaact0773C Assessee Revenue [Assessment Year: 2013-14] Additional Commissioner Of M/S Timex Group India Ltd. Income Tax, Special Range-9, 106-107, Ambadeep Building, New Delhi-110002 Vs Kasturba Gandhi Marg, New Delhi-110001 Pan-Aaact0773C Revenue Assessee Assessee By Shri Tushar Jarwal, Adv. Shri Aayush Nagpal, Adv. & Shri Vikrant Maheshwari, Adv. Revenue By Shri Rohit Garg, Cit-Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 26.09.2025

Section 143(3)Section 40Section 92Section 92BSection 92C

outset, the Ld. AR referring to its letter dated 02.04.2025 placed before us submitted that the assessee has entered into unilateral Advance Pricing Agreement (APA) under Section 92CC of the Act, (hereinafter referred to as the ‘Act’) dated 29.11.2019 relating to AMP expenses subject matter of dispute in the department ... therefore, the department’s appeal does not survive, as it relates only to TP issues. It was further submitted that aof the advance pricing agreement dated 29.11.2019 was also annexed with the said letter. Based on the said agreement and the ITAT’s order sheet noting dated

SAMSUNG INDIA ELECTRONICS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-22(2), DELHI

In the result, the appeal of the assessee is partly allowed

ITA 5256/DEL/2024[2021-22]Status: DisposedITAT Delhi25 Sept 2025AY 2021-22

Bench: Shri Challa Nagendram Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Dharam Veer Singh, CIT-DR
Section 143(3)Section 80G

issued the rectified final assessment order dated 18 December 2024, incorporating the revised transfer pricing adjustment. Coverage of transfer pricing grounds under the Advance Pricing Agreement It is noteworthy that the following facts were brought to the attention of the Hon'ble Tribunal in the hearing scheduled on 14 January ... Advance Pricing Agreement ('APA') application was filed by the Applicant dated 30 March 2017, covering the financial year ('FY') 2017-18 to FY 2021-22 (corresponding to AY 2018- 19 to AY 2022-23). The transfer pricing related grounds (i.e. Ground no. 2 to Ground no. 27) in the subject

SAMSUNG INDIA ELECTRONICS PRIVATE LIMITED,NEW DELHI vs. ITO, DELHI

In the result, the appeal of the assessee is partly allowed

ITA 3724/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Sept 2025AY 2020-21

Bench: Shri Challa Nagendram Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Dharam Veer Singh, CIT-DR
Section 143(3)Section 80G

issued the rectified final assessment order dated 18 December 2024, incorporating the revised transfer pricing adjustment. Coverage of transfer pricing grounds under the Advance Pricing Agreement It is noteworthy that the following facts were brought to the attention of the Hon'ble Tribunal in the hearing scheduled on 14 January ... Advance Pricing Agreement ('APA') application was filed by the Applicant dated 30 March 2017, covering the financial year ('FY') 2017-18 to FY 2021-22 (corresponding to AY 2018- 19 to AY 2022-23). The transfer pricing related grounds (i.e. Ground no. 2 to Ground no. 27) in the subject

GEMOLOGICAL INSTITUTE OF AMERICA, INC.,UNITED STATES vs. THE ASSISTANT COMMISSIONER OF INCOME-TA (INTERNATIONAL TAXATION) - CIRCLE 2(3)(2), MUMBAI

In the result, appeals of the assesse are allowed partly for statistical\npurposes

ITA 1293/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Sept 2025AY 2022-23
For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R
Section 144C(13)Section 147Section 148

Article 12(2) of the India-USA Double Taxation Avoidance\nAgreement ['DTAA'] should be restricted to the amount determined in accordance\nwith the Advanced Pricing Agreement ['APA'], if any, entered into by GIA India\nLaboratory Private Limited with the Central Board of Direct Taxes ['CBDT'].\n8 : 2 The Appellant submits ... nDate of the Final Assessment Order passed u/s.147 r.w.s.144C(13) of\nthe Income-tax Act, 1961\n30 December 2024\nDate when the Advance Pricing Agreement [\"APA\"] was concluded\nbetween GIA India Laboratory Private Limited and the Central\nBoard of Direct Taxes\n27 March 2025\nDate of the invoice/debit note raised

GEMOLOGICAL INSTITUTE OF AMERICA, INC.,UNITED STATES vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(3)(2) - MUMBAI, MUMBAI

In the result, appeals of the assesse are allowed partly for statistical\npurposes

ITA 1292/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20
For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R
Section 147Section 148

Article 12(2) of the India-USA Double Taxation Avoidance\nAgreement ['DTAA'] should be restricted to the amount determined in accordance\nwith the Advanced Pricing Agreement ['APA'], if any, entered into by GIA India\nLaboratory Private Limited with the Central Board of Direct Taxes ['CBDT'].\n8 : 2 The Appellant submits ... Assessment Order passed u/s.147 r.w.s.144C(13) of\nthe Income-tax Act, 1961\n30 December 2024\n4,54,85,72,731\nDate when the Advance Pricing Agreement [\"APA\"] was concluded\nbetween GIA India Laboratory Private Limited and the Central\nBoard of Direct Taxes\n27 March 2025\nDate of the invoice/debit note

J P MORGAN SERVICES INDIA PVT LTD,MUMBAI vs. DCIT CIRCLE 2(2)(1), MUMBAI

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

ITA 6563/MUM/2024[2021-22]Status: DisposedITAT Mumbai26 Aug 2025AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalj P Morgan Services India Private Limited Tower A Blk 9, Tower B Blk 10, Tower C Blk 11, Nirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai Suburban, ............... Appellant 400063. Pan : Aabcd0503B V/S Deputy Commissioner Of Income-Tax, Circle 2(2)(1), ……………… Respondent Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai-400020. Assessee By : Shri Fenil Bhatt Revenue By : Ms. Neena Jeph, Cit.Dr

For Appellant: Shri Fenil BhattFor Respondent: Ms. Neena Jeph, CIT.DR
Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 153Section 92D

assessee seeking withdrawal of the grounds no. 5 - 13, raised in assessee’s appeal, pertaining to transfer pricing adjustment in view of the Advance Pricing Agreement (“APA”) entered with the CBDT, which also covers the year under consideration. In the afore-noted letter, the assessee submits that since

DCIT, CIRCLE- 5(2), NEW DELHI vs. CARLSBERG INDIA PVT. LTD., NEW DELHI

In the result, the appeal filed by the assessee is allowed and appeal filed by the Revenue stands dismissed

ITA 3190/DEL/2019[2010-11]Status: DisposedITAT Delhi31 Jul 2025AY 2010-11

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalcarlsberg India Private Limited, Dy. Cit, 4Th Floor, Rectangle No.1, Circle-5(2), Commercial Complex,D-4, Saket, Vs. New Delhi. New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) (Assessment Year 2010-11 Dy. Cit, Carlsberg India Private Circle-5(2), Limited, New Delhi. Vs. 4Th Floor, Rectangle No.1, Commercial Complex, D-4, Saket, New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) Assessee By Shri S.K. Aggarwal, Ca & Shri Paras Sharma, Ar & Ms. Ruchika Mittal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 Order

Section 143(1)Section 14ASection 36(1)(iii)

Lastly it is pointed out that the Ld. CIT(A) has further observed that the assessee has entered into Advance Pricing Agreement with CBDT and carried out a role back of four years from Assessment Year 2011-12 to 2014-15. After applying a rate of 3.5% of the gross

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