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“transfer pricing adjustment”

Transfer PricingSection 92CSection 92C2,153 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

92CA of the Act was made to the TPO for determination of ALP in respect of international transactions and specified domestic transactions. Several transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before us in the following ... dated 2 25.10.2022 which are also in contradiction to the directions of ld. DRP; b) 29,45,91,940/- on account of various transfer pricing adjustments proposed by Id. TPO and upheld by the Id. DRP, c) ₹5,44,84,880/-on account of corporate tax issue upheld

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

reference under section 92CA of the Act was made to the TPO for determination of ALP in respect of specified domestic transactions. Certain transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before us in the following ... additions/disallowances made by Ld. AO Ld. DRP's are wholly illegal, untenable and on erroneous grounds. GROUNDS OF APPEAL IN RESPECT OF TRANSFER PRICING ADJUSTMENT Transfer of Steam - Adjustment of ₹107,01,24,795/- 5. That without prejudice to above grounds, the Ld. DRP/TPO and consequently the Id. AO have

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

issues were referred to the Transfer Pricing Officer for determination of Arm’s Length Price (ALP). The Transfer Pricing Officer suggested that the transfer pricing adjustment of Rs. Mahalaxmi Continental Ltd. Vs DCIT/ACIT 50,64,220/- to the specified domestic transactions by the assessee. Consequently, the AO added the same

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

issues were referred to the Transfer Pricing Officer for determination of Arm’s Length Price (ALP). The Transfer Pricing Officer suggested that the transfer pricing adjustment of Rs. Mahalaxmi Continental Ltd. Vs DCIT/ACIT 50,64,220/- to the specified domestic transactions by the assessee. Consequently, the AO added the same

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

appeal before the Tribunal. We take up grounds raised by the Revenue, seriatim. 4. Ground nos.1 and 2 are in respect of transfer pricing adjustment on account of export of pharmaceutical products to two of its AEs, Glenmark Nigeria and Glenmark Czech. Ld. TPO observed that assessee had earned lower ... assessee should be accepted. Accordingly, we set aside the order passed by Ld CIT(A) and direct the AO to delete the transfer pricing adjustment made in respect of exports made to M/s Glenmark, South Africa and M/s Glenmark, Mexico” 4.3. On these set of facts, ld. CIT(A) found

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

appeal before the Tribunal. We take up grounds raised by the Revenue, seriatim. 4. Ground nos.1 and 2 are in respect of transfer pricing adjustment on account of export of pharmaceutical products to two of its AEs, Glenmark Nigeria and Glenmark Czech. Ld. TPO observed that assessee had earned lower ... assessee should be accepted. Accordingly, we set aside the order passed by Ld CIT(A) and direct the AO to delete the transfer pricing adjustment made in respect of exports made to M/s Glenmark, South Africa and M/s Glenmark, Mexico” 4.3. On these set of facts, ld. CIT(A) found

FIRSTRAND BANK LIMITED - INDIA BRANCH,MUMBAI vs. ASSISTANT COMMISSIONER , MUMBAI

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 133(6)Section 144C(5)Section 92C

determining rmining the the arm's length commission, thereby making enhancement of Rs. 75,00,000 to the th transfer transfer pricing adjustment.” 2.1. The only issue involved in the present appeal is in respect of determination of guarantee commission for which an upward adjustment has been made ... Guarantee commission charged by assessee @ 93,33,826 0.31% (INR 300Cr/1.11Cr) (A) Guarantee commission as per ALP @ 1.55 (B) 4,65,00,000 Transfer Pricing Adjustment (B-A) 3,71,66,174 3.2. Assessee raised its objections before the ld. DRP, who after considering the submissions, rejected the same

CA (INDIA) TECHNOLOGIES P.LTD,MUMBAI vs. ITO RG 14(1)(4), MUMBAI

In the result, the appeal is dismissed

ITA 7381/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey, Vp & Shri Makarand Vasant Mahadeokar, Am Ca (India) Technologies Private The Income Tax Officer-14(1)(4) Limited Room No. 458, Aayakar Bhavan, Ground Floor, Vibgyor Tower, Mumbai-400 020 Plot C-62, G-Block, Vs. Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Aaacc 4971 D (Appellant) : (Respondent) Appellant By : None Respondent By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 06.03.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Makarand V. Mahadeokar, Am: This Is An Appeal By The Assessee Against Order Dated 18.09.2018 Of First Appellate Authority, Pertaining To Assessment Year (A.Y.) 2014-15. 2. The Assessee Vide Letter Dated 26.02.2026 Has Submitted That The Dispute Has Been Resolved Through Mutual Agreement Procedure (“Map”) & The Assessee Has Accepted The Map Resolution, Hence, Request Has Been Made For Withdrawal Of The Appeal. The Contents Of The Said Letter Are As Under: Dear Sir, Re: Ca (India) Technologies Private Limited ('Ca India' Or 'Appellant') Permanent Account Number ('Pan'): Aaacc4971D Assessment Year ('Ay'): 2014-15 Appeal No. Ita 7381/Mum/2018

For Appellant: NoneFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C

aforesaid communication in enclosed herewith Annexure 1 4. The MAP resolution has specified the relief to be granted on account of transfer pricing adjustment in relation to the transaction involving SWD and Royalty. A tabular presentation of the total adjustments made by the Ld. AO and the adjustments sustained/relieved

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. LOYAL TEXTILE MILLS LTD, KOVILPATTI

In the result, the appeal filed by the Revenue is dismissed

ITA 2308/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Mar 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. Bhupendran, Advocate (Virtual)
Section 143(3)Section 40Section 801ASection 80ISection 92CSection 92F

Aggrieved, the Revenue is in appeal before us. :-3-: ITA No: 2308/Chny/2025 5. The Revenue has challenged two issues: a. The deletion of transfer pricing adjustment in respect of captive power valuation for the purpose of deduction u/s.80IA of the Act. b. The deletion of disallowance u/s.40

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

length. The Hon'ble ITAT, in those years, not only accepted the royalty transactions as legitimate business expenditures but also deleted the transfer pricing adjustments made by the TPO. These decisions have not been reversed as of the date of this order. 4.9. Further, commercial expediency of the royalty transaction ... basis of the aforesaid reasoning, we uphold the decision of the learned Commissioner (Appeals) in deleting the addition made on account of transfer pricing adjustment.” 8. On a careful reading of the aforesaid order of the Tribunal, it becomes very much clear that there are no material difference in facts

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

length. The Hon'ble ITAT, in those years, not only accepted the royalty transactions as legitimate business expenditures but also deleted the transfer pricing adjustments made by the TPO. These decisions have not been reversed as of the date of this order. 4.9. Further, commercial expediency of the royalty transaction ... basis of the aforesaid reasoning, we uphold the decision of the learned Commissioner (Appeals) in deleting the addition made on account of transfer pricing adjustment.” 8. On a careful reading of the aforesaid order of the Tribunal, it becomes very much clear that there are no material difference in facts

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

assessee’s own case for AY 2015-16 in ITA Nos. 222 & 281/Ahd/2021 vide order dated 21.05.2025. Ground Nos. 1 & 2 – Transfer Pricing Adjustment on Interest on Loans to AEs 4. These grounds relate to the deletion of upward adjustment of Rs.1,27,16,929/- made by the TPO/AO ... assessee’s own case for AY 2015-16, wherein the Tribunal, after detailed examination, held as under:- “Ground No. 1(i) - Transfer Pricing Adjustment on Interest on Advances to Associated Enterprises 5. The assessee had during the year under consideration advanced loans to its Associated Enterprises (AEs) in foreign currency

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

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

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22
For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)
Section 143(3)

assessee filed an appeal before us\n18.1 The Ld. AR before us submitted that the lower authorities erred in\nmaking a transfer-pricing adjustment of ₹0.56 crores on account of\nnotional interest on the appellant's outstanding trade receivables from its\nassociated enterprises. It was contended that the learned ... order\nAsst. Registrar, ITAT, Bangalore", "summary": { "facts": "The assessee, Parametric Technology (India) Pvt. Ltd., appealed against the order of the AO/TPO concerning transfer pricing adjustments for AY 2021-22. The primary issue involved the inclusion/exclusion of comparable companies for benchmarking international transactions, specifically concerning the Software Development (SWD) and Software

ACIT, CIRCLE-1(1)(1), VADODARA vs. FARMSON PHARMACEUTICAL GUJARAT PRIVATE LIMITED, VADODARA

In the result, the appeal of the Revenue is dismissed

ITA 1835/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2015-16

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 115JSection 144(1)Section 37Section 92BSection 92CSection 92E

under:- “(1) Whether on the facts and in circumstances of the case and in law, the Ld.CIT(A) was justified in deleting the transfer pricing adjustment by holding that the omission of section 92BA(i) of the Act, 1961 rendered the provision non-existent ab initio, without appreciating that ... form of 3CEB u/s. 92E of the Act. The ld. D.R. further submitted that the CIT(A) was not justified in deleting transfer pricing adjustment by holding that the omission of section 92BA(1) of the Act, 1961 rendered the provision as non-existent ab initio without appreciating that

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

ECBs") and making an upward adjustment of INR.62,88,86,271/- 1.1. The learned TPO/ AO has erred in determining a transfer pricing adjustment on account of the interest on ECB amounting to INR 62,88,86,271. 1.2. The learned TPO/ AO has erred in disregarding the benchmarking conducted

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

conducting comparability analysis;\n9.\nLd. AO/TPO pursuant to the directions of the Hon'ble DRP erred, in\nlaw and facts, in determining separate transfer pricing adjustment\non account of the interest on outstanding receivables amounting to\nINR 72,817,000\n10.\nWithout prejudice to our ground of appeal ... n3.7.\nFurther, TPO rejected the Assessee's contention that no separate\nadjustments was warranted in respect of interest on overdue\nreceivables and proposed Transfer Pricing Adjustment of\nINR.72,817,800/- in respect of interest calculated on receivables\ntaking LIBOR-6 months + 400 basis points applicable for the\nFinancial Year

DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 1560/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

case.\n2 \"On facts and circumstances of the case and in law the Ld CIT(A) erred in\nholding that no transfer pricing adjustments was required to be made on\naccount of the comfort letter given by the assessee on behalf of its AE to the\nMonetary Authority of Singapore ... facts and circumstances of the case and in law the Ld CIT(A) erred in\nholding that no transfer pricing adjustments was required to be made on\naccount of the comfort letter given by the assessee on behalf of its AE to the\nMonetary Authority of Singapore, thereby overlooking Section

ICICI BANK LTD,MUMBAI vs. DCIT 2(3)(2), MUMBAI

Appeal is partly allowed

ITA 1446/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

case.\n2 \"On facts and circumstances of the case and in law the Ld CIT(A) erred in\nholding that no transfer pricing adjustments was required to be made on\naccount of the comfort letter given by the assessee on behalf of its AE to the\nMonetary Authority of Singapore ... facts and circumstances of the case and in law the Ld CIT(A) erred in\nholding that no transfer pricing adjustments was required to be made on\naccount of the comfort letter given by the assessee on behalf of its AE to the\nMonetary Authority of Singapore, thereby overlooking Section

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 133(6)Section 92D

assessment years 2009-10\n& 2010-11 on following grounds of appeal:\n Assessment Year 2009-10\nGround 1- Transfer Pricing Adjustment relating to Data\nProcessing Services Rs. 11,97,15,774 and Software Services Rs.\n6,34,82,242\n1.1. On the facts and in the circumstances ... expenditure in the assessment orders of\n assessment year 2004-05, 2005- 06 and 2006-07.\n Assessment Year 2010-11\nGround 1 Transfer Pricing Adjustment relating to Data Processing\nServices Rs. 9,01,18,424 and Software Services Rs. 5,95,81,859\nAdjudicated relying on charts enclosed

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeals filed by the assessee stands partly allowed

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

orders dated 23.01.2014 and 06.01.2015 for assessment years 2009-10 & 2010-11 on following grounds of appeal: Assessment Year 2009-10 Ground 1- Transfer Pricing Adjustment relating to Data Processing Services Rs. 11,97,15,774 and Software Services Rs. 6,34,82,242 1.1. On the facts ... revenue expenditure in the assessment orders of assessment year 2004-05, 2005- 06 and 2006-07. Assessment Year 2010-11 Ground 1 Transfer Pricing Adjustment relating to Data Processing Services Rs. 9,01,18,424 and Software Services Rs. 5,95,81,859 - Adjudicated relying on charts enclosed at Page

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