“transfer pricing adjustment”

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

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

documentary evidences which demonstrate receipt of services by the appellant and computing the ALP of the transaction at NIL and consequently making a transfer pricing adjustment 6. On facts and in the circumstances of the case and in law, the learned TPO, the AO and the Hon'ble DRP have ... raised is not pressed by the assessee. Accordingly, ground no.4 stands dismissed. 10. Ground No.5-10 relate to the assessee's challenge to the transfer pricing adjustment by which the TPO determined the ALP of the management service fees paid to its AE for intra-group services

DCIT-14(1)(2), Mumbai vs. M/S. Ekta Everglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri

following grounds:- “1. On facts and circumstances of the case and in law the Id. CIT(A) Tax has erred in deleting the Transfer Pricing adjustment on account of difference between the interest paid by the assessee to its AE and its Arm's Length Price. 2 On facts ... orders of the revenue authorities. The limited issue before us is whether the Ld. CIT(A) was justified in deleting the transfer pricing adjustment of Rs.1,31,10,958/- towards interest on CCDs issued to the AE. The material facts remain undisputed. The assessee issued fully compulsorily convertible debentures (CCDs

DCIT-14(1)(2), Mumbai vs. M/S. Ekta Everglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri

following grounds:- 1. On facts and circumstances of the case and in law the Id. CIT(A) Tax has erred in deleting the Transfer Pricing adjustment on account of difference between the interest paid by the assessee to its AE and its Arm's Length Price. 2 On facts ... orders of the revenue authorities. The limited issue before us is whether the Ld. CIT(A) was justified in deleting the transfer pricing adjustment of Rs.1,31,10,958/- towards interest on CCDs issued to the AE. The material facts remain undisputed. The assessee issued fully compulsorily convertible debentures (CCDs

DCIT-14(1)(2), Mumbai vs. M/S. Ekta Everglade Homes Pvt Ltd., Mumbai

following grounds:- “1. On facts and circumstances of the case and in law the Id. CIT(A) Tax has erred in deleting the Transfer Pricing adjustment on account of difference between the interest paid by the assessee to its AE and its Arm's Length Price. 2 On facts

DCIT, Cir-14(1)(2), Mumbai vs. M/S. Ekta Eveglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

following grounds:- “1. On facts and circumstances of the case and in law the Id. CIT(A) Tax has erred in deleting the Transfer Pricing adjustment on account of difference between the interest paid by the assessee to its AE and its Arm's Length Price. 2 On facts ... orders of the revenue authorities. The limited issue before us is whether the Ld. CIT(A) was justified in deleting the transfer pricing adjustment of Rs.1,31,10,958/- towards interest on CCDs issued to the AE. The material facts remain undisputed. The assessee issued fully compulsorily convertible debentures (CCDs

Dsv Air & Sea Private Limited, Mumbai vs. ACIT, Cirle-3(1)(1), Mumbai

In the result, this ground of appeal is allowed for statistical purpose

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

passed final assessment order dated 30/05/2024 under section 144C(13) of the Act. Aggrieved by the addition / adjustment on account of transfer pricing adjustment, the assessee has filed present appeal before the Tribunal. 3. We have heard the submission of Ld.Authorised Representative of the assessee (Ld.AR) and the learned Senior ... following 17 additional comparables and determined arm’s length range to be 3.09% to 4.3% with a mean margin of 3.9% and suggested transfer pricing adjustment of Rs. 8.005 Crore. The TPO introduced following new comparables; Sr. Name of comparables Margins as pr No TP Order 1 Prakash Parcel Services

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

list of comparables" 4 On facts and circumstances of the case and in law the Ld CIT(A) erred in holding that 'no transfer pricing adjustments was required to be made on account of the comfort letter given by the assessee on behalf of its AE to the Monetary Authority ... ΑΕ." 5 On facts and circumstances of the case and in law the Ld CIT(A) erred in holding that "no transfer pricing adjustments was required to be made on account of the comfort letter given by the assessee on behalf of its AE to the Monetary Authority of Singapore

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

list of comparables" 4 On facts and circumstances of the case and in law the Ld CIT(A) erred in holding that 'no transfer pricing adjustments was required to be made on account of the comfort letter given by the assessee on behalf of its AE to the Monetary Authority ... ΑΕ." 5 On facts and circumstances of the case and in law the Ld CIT(A) erred in holding that "no transfer pricing adjustments was required to be made on account of the comfort letter given by the assessee on behalf of its AE to the Monetary Authority of Singapore

Daiwa Capital Markets India Private Limited, Lower Parel vs. Asst Commissioner of Income Tax Circle 4 1 1 Mumbai, Mumbai

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

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhandaiwa Capital Markets India Acit Circle 4(1)(1), Private Limited Room No. 640, 6Th Floor, Office No. N10 & N11, 9Th Floor, Vs. Aayakar Bhavan, M.K. Road, Dextrus-Peninsula Tower, Peninsula Mumbai-400 020 Corporate Park, G. K. Marg, Lower Parel, Delisle Road, Mumbai-400 013 Pan: Aaccd7178B (Appellant) (Respondent) Assessee Represented By : Ms. Shivali Mhatre, Ld. Ar Department Represented By : Shri Annavaram Kosuri, Ld. Dr Date Of Conclusion Of Hearing : 03.11.2025 Date Of Pronouncement : 20.11.2025

scrutiny and assessment proceedings were completed under section 143(3) of the Act vide order dated 19/01/2017 whereby the AO made a transfer pricing adjustment which was subsequently deleted by the Ld. CIT(A). During the proceedings, the assessee was not aware of the genuine TDS credit and accordingly ... this additional TDS. 6.2. Later on, the case was selected for scrutiny and order u/s. 143(3) was passed on 19.01.2017 making Transfer Pricing adjustments. Even during the course of scrutiny assessment proceedings before the AO also, no fresh claim for additional TDS credit was ever made by the appellant

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

while considering the TPO’s order and draft assessment order by the AO, ultimately rejected the objections raised by the Assessee against the transfer pricing adjustment of Rs.8,32,83,536/- (Rs.6,60,82,190/- on account of GIS services + Rs.1,72,01,346/- on account of GSA services ... comparables to see if any increase in the total income of the enterprise chargeable to tax in India, is warranted on account of transfer pricing adjustment. The contention of the Id. AR for considering the profit of the foreign/AE as 'profit A' for the purposes of comparison with profit

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

issued by the Dispute Resolution Panel, Mumbai, under section 144C(5) for the assessment year 2020–21. The controversy before us straddles substantial transfer pricing adjustments across multiple business segments of the assessee, together with certain corporate tax disallowances and consequential issues, all resting on a detailed factual and legal ... transfer pricing documentation and carrying out his analysis, passed an order dated 29 July 2023 under section 92CA(3). He proposed an aggregate transfer pricing adjustment of Rs. 536,75,63,935/- across various streams of services, namely: (i) provision of SBO IT services from Bengaluru; (ii) provision