“benchmarking analysis”

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

deleting the addition of Rs.3,29,72,122/- to the income of the assessee company made by the Transfer Pricing Officer by disregarding the benchmarking analysis carried out by the TPO as per stipulated provisions of the Income-tax Act and Rules? (Tax Effect (1 & 2): Rs.1 ... deleting the addition of Rs. 6,17,842/- to the income of the assessee company made by the Transfer Pricing Officer by disregarding the benchmarking analysis carried out by the TPO as per stipulated provisions of the Income-tax Act and Rules? 1 & 2: Tax Effect

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

deleting the addition of Rs.3,29,72,122/- to the income of the assessee company made by the Transfer Pricing Officer by disregarding the benchmarking analysis carried out by the TPO as per stipulated provisions of the Income-tax Act and Rules? (Tax Effect (1 & 2): Rs.1 ... deleting the addition of Rs. 6,17,842/- to the income of the assessee company made by the Transfer Pricing Officer by disregarding the benchmarking analysis carried out by the TPO as per stipulated provisions of the Income-tax Act and Rules? 1 & 2: Tax Effect

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

facts and in law in disregarding the various submissions made by the\nAppellant without providing any cogent reasons thereof and also\nerroneously rejected the benchmarking analysis and comparable\ncompanies selected by the Appellant without appreciating the fact that\nsuch selection was based on contemporaneous data and the transfer\npricing study ... facts and in law in disregarding the various submissions made by the\nAppellant without providing any cogent reasons thereof and also\nerroneously rejected the benchmarking analysis and comparable\ncompanies selected by the Appellant without appreciating the fact that\nsuch selection was based on contemporaneous data and the transfer\npricing study

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

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

facts and in law in disregarding the various submissions made by the Appellant without providing any cogent reasons thereof and also erroneously rejected the benchmarking analysis and comparable companies selected by the Appellant without appreciating the fact that such selection was based on contemporaneous data and the transfer pricing study ... facts and in law in disregarding the various submissions made by the Appellant without providing any cogent reasons thereof and also erroneously rejected the benchmarking analysis and comparable companies selected by the Appellant without appreciating the fact that such selection was based on contemporaneous data and the transfer pricing study

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

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“J” BENCH, MUMBAI\nBEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER)\n&\nSHRI

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

{"clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“J” BENCH, MUMBAI\nBEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER)\n&\nSHRI

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

June 2024 incorporated the aforesaid adjustments. The assessee filed detailed objections before the DRP. During the DRP proceedings, the assessee also furnished a fresh benchmarking analysis as additional evidence, applying even the filters suggested by the TPO, on a without prejudice basis. The DRP forwarded the additional evidence ... geographical destination of the goods. 33. It was further submitted that even during the proceedings before the DRP, the assessee had furnished a fresh benchmarking analysis, applying the filters suggested by the TPO, on a without prejudice basis. However, those comparables were also rejected. It was argued that the conclusion

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

June 2024\nincorporated the aforesaid adjustments. The assessee filed\ndetailed objections before the DRP. During the DRP proceedings,\nthe assessee also furnished a fresh benchmarking analysis as\nadditional evidence, applying even the filters suggested by the\nTPO, on a without prejudice basis. The DRP forwarded the\nadditional evidence ... range reflected in\nChart 1, we hold that the rejection of the entire comparable set\nselected by the assessee is not sustainable.\n68. The benchmarking analysis undertaken by the assessee\nunder External TNMM is found to be robust, scientifically\nconducted and aligned with Rule 10B. The assessee's AE segment

FIRSTRAND BANK LIMITED,MUMBAI vs. THE ASSISTANT COMM. OF INCOME TAX-CIRCLE-2(3)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Firstrand Bank Limited The Assistant Commissioner Of C-53, G-Block, 5 Th Floor, Income-Tax, Tcg Financial Centre, Circle-2(3)(1), Bandra-Kurla Complex, Mumbai Vs. Bandra (East)., Mumbai -400051 (Pan: Aabcf1632P) (Appellant) (Respondent) Present For: Assessee : Shri Paras Savla, 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 Ld. Dispute Resolution Panel- 1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2022- 23/1043517868(1), Dated 22.06.2022, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under:

most appropriate method exact comparability is not required since certain degree of functional dilution of tolerance is permissible, given the broader nature of benchmarking analysis under this method. 8.1. For the other two comparables namely CRISIL Risk and Infrastructure Solutions Ltd. and ICRA Management Consulting Services Ltd. which were excluded ... required rather certain 13 FirstRand Bank Limited AY 2018-19 degree of functional dilution of tolerance is permissible given broader nature of benchmarking analysis under this method. We also note in respect of CRISIL that ld. TPO had applied turnover filter of more than 10 times for which assessee claims

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

sale/purchase of power between CPP-2 and Rayon Plant qualifies as SDT u/s. 92BA of the Act. Even, the assessee had undertaken a benchmarking analysis of the SDT. Since, in the year under consideration, the Rayon Plant had also purchased power from a State owned distribution licensee at Rs.6.62

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, C.O. filed by assessee is\ndismissed as infructuous

nsale/purchase of power between CPP-2 and Rayon Plant qualifies as SDT u/s.\n92BA of the Act. Even, the assessee had undertaken a benchmarking analysis of\nthe SDT. Since, in the year under consideration, the Rayon Plant had also\npurchased power from a State owned distribution licensee at Rs.6.62