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“contemporaneous data”

Transfer PricingSection 92CSection 92C79 judgments

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

Income Tax Act, 1961; 1.6. The TPO/ AO/ DRP has disregarded the fact that the fresh search is not conducted on the basis of contemporaneous data available in the public domain; 1.7. The AO/DRP has erred in determining arm's length guarantee rate at 1.80% for benchmarking guarantee transaction

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

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 report prepared and maintained as per Section 92D of the\nAct read with Rule 10D of the Income-tax Rules ... 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 report prepared and maintained as per Section 92D of the\nAct read with Rule 10D of the Income-tax Rules

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

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 report prepared and maintained as per Section 92D of the Act read with Rule 10D of the Income-tax Rules ... 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 report prepared and maintained as per Section 92D of the Act read with Rule 10D of the Income-tax Rules

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

ITA 2502/MUM/2022[2018-2019]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-2019

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:

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Annavaram K, Sr. DR
Section 144C(5)Section 40Section 9(1)(vi)

Analytics Pvt Ltd 1:3 The AO/ TPO/ DRP erred in not appreciating that the fresh search is not conducted on the basis of contemporaneous data available in the public domain and thus is bad in law; 1:4 The AO/TPO/ DRP erred in selecting companies viz. India Life Capital

HONDA TRADING CORPORATION INDIA PRIVATE LIMITED,NEW DELHI vs. DC/ACIT, CIRCLE 10(1), DELHI / ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NEW DELHI

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

ITA 5286/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144Section 144CSection 92C

companies having turnover less than one crore; and Reject companies with different accounting year end. 10. Impugned order erred in not considering use of contemporaneous data and thereby accepting companies as comparable for which the financial data was not available with the Assessee at the time of preparation of transfer

COMPASS INDIA SUPPORT SERVICES PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

ITA 511/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18
Section 143(3)

Assessee and conducted a fresh\nsearch based on the recent cut-off date. The Assessee had conducted the\ncomparability analysis on the basis of contemporaneous data and same should be\naccepted\nRejected the filters applied by the Assessee based on inappropriate assumptions for\ndoing so and applied additional filters

COMPASS INDIA SUPPORT SERVICES PRIVATE LTD. ,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

ITA 1383/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19
Section 143(3)

Assessee and conducted a fresh\nsearch based on the recent cut-off date. The Assessee had conducted the\ncomparability analysis on the basis of contemporaneous data and same should be\naccepted\nRejected the filters applied by the Assessee based on inappropriate assumptions for\ndoing so and applied additional filters

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

ITA 1597/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course\nof assessment and showed that these contract(s) were awarded through\nan open tender process, and the contemporaneous data showed that the\nrates at which coal were supplied by A Co & K Co were commensurate or\nlower to the rates at which other

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course of assessment and showed that these contract(s) were awarded through an open tender process, and the contemporaneous data showed that the rates at which coal were supplied by A Co & K Co were commensurate or lower to the rates at which other

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course\nof assessment and showed that these contract(s) were awarded through\nan open tender process, and the contemporaneous data showed that the\nrates at which coal were supplied by A Co & K Co were commensurate or\nlower to the rates at which other

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

ITA 1323/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course\nof assessment and showed that these contract(s) were awarded through\nan open tender process, and the contemporaneous data showed that the\nrates at which coal were supplied by A Co & K Co were commensurate or\nlower to the rates at which other

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1322/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course\nof assessment and showed that these contract(s) were awarded through\nan open tender process, and the contemporaneous data showed that the\nrates at which coal were supplied by A Co & K Co were commensurate or\nlower to the rates at which other

R.VISWANATHAN,,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1321/CHNY/2025[2014-15]Status: DisposedITAT Chennai22 Jan 2026AY 2014-15
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

made by the AO in the course\nof assessment and showed that these contract(s) were awarded through\nan open tender process, and the contemporaneous data showed that the\nrates at which coal were supplied by A Co & K Co were commensurate or\nlower to the rates at which other

DR. C. VIJAYABASKAR,PUDUKOTTAI vs. DCIT, CENTRAL CIRCLE-2(1), CHENNAI

In the result, the appeal(s) of the assessee for AY 2016-17 is partly

ITA 591/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Jan 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

accounts nor invoked provisions of Section 145(3) before making the estimated disallowance. The Ld. AR for the assessee has further submitted before us contemporaneous data which shows that, after providing for the entire quarry expenses, the gross profit of the assessee across all the years was in the range

DR. C. VIJAYABASKAR,PUDUKOTTAI vs. DCIT, CENTRAL CIRCLE-2(1), CHENNAI

In the result, the appeal(s) of the assessee for AY 2016-17 is partly

ITA 590/CHNY/2023[2017-18]Status: DisposedITAT Chennai14 Jan 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

accounts nor invoked provisions of Section 145(3) before making the estimated disallowance. The Ld. AR for the assessee has further submitted before us contemporaneous data which shows that, after providing for the entire quarry expenses, the gross profit of the assessee across all the years was in the range

DR. C. VIJAYABASKAR,PUDUKOTTAI vs. DCIT, CENTRAL CIRCLE-2(1), CHENNAI

In the result, the appeal(s) of the assessee for AY 2016-17 is partly

ITA 589/CHNY/2023[2016-17]Status: DisposedITAT Chennai14 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

accounts nor invoked provisions of Section 145(3) before making the estimated disallowance. The Ld. AR for the assessee has further submitted before us contemporaneous data which shows that, after providing for the entire quarry expenses, the gross profit of the assessee across all the years was in the range

NTT DATA GLOBAL DELIVERY SERVICES PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 2062/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

different financial year ending. The ld. DRP held that companies must have the same financial year ending as required under the Act for contemporaneous data. Because these conditions were not satisfied, the company could not be included. 14.7 For R Systems International Ltd., the learned DRP held that the company

NTT DATA GLOBAL DELIVERY SERVICES PVT LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BANGALORE

In the result appeal of the assessee is partly allowed for statistical purposes

ITA 1720/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Dec 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K.J – CIT

different financial year ending. The ld. DRP held that companies must have the same financial year ending as required under the Act for contemporaneous data. Because these conditions were not satisfied, the company could not be included. 14.7 For R Systems International Ltd., the learned DRP held that the company

CALLIDUSCLOUD (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE- 1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1395/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153

income is less than 75% of sales vi. Exclusion of companies whose employee cost is less than 25% of turnover (b) Use of non-contemporaneous data not available in the public domain at the time of preparing TP documentation. (c) Inclusion of companies exceeding ₹200 crore turnover filter: i. Mindtree ... project execution. 4.2.4. Appellant provides high-end, information-based services. 4.3. Errors in comparability analysis similar to SWD objections including turnover filter, functionality, contemporaneous data and exclusion/inclusion of companies: Companies wrongly included: i. Happiest Minds Technologies Limited ii. L&T Technology Services Limited iii. Sagacious Research Private Limited

VERMEIREN INDIA REHAB PRIVATE LIMITED,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATI

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

ITA 1315/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Sandeep Bagmar R, AdvocateFor Respondent: MS. U. Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 32

argued that, the companies with non-March year-ends should not be automatically rejected. As per Rule-10B(4) of the Act, which requires contemporaneous data and not strict financial year end matching and, therefore, data overlapping the financial year, should be considered. Further, he submitted that

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