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“contemporaneous data”

Transfer PricingSection 92CSection 92C79 judgments

The decision most relied on for contemporaneous data is DCIT v. Rehau Polymers Pvt. Ltd. (85 Taxmann.com 23), cited in 17 judgments on BharatTax.

Leading authorities on contemporaneous data

DCIT v. Rehau Polymers Pvt. Ltd.
85 Taxmann.com 23 · 2017 · Reported
17
citing judgments

The case is cited for principles related to transfer pricing, likely concerning the benchmarking analysis of related party transactions, as indicated by the accompanying topics and keywords.

Lionbridge Technologies (P.) Ltd. v. ITO
77 Taxmann.com 48 · 2017 · Reported
10
citing judgments

This case does not lay down a clear proposition of law based on the provided excerpts. The passages focus on listing other cases and describing the business of a company rather than stating a legal holding.

Judgments citing contemporaneous data

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

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

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

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

submitted that, under instructions from the assessee, he was not pressing Ground Nos.2.3 and 2.4 (relating to the legal challenge on use of non- contemporaneous data) and Ground Nos.2.7 and 2.8 (relating to working capital and risk adjustments) as independent, freestanding grounds. He clarified, however, that such non-pressing ... this stage we raised a query to Ld. AR as to why the assessee is not pressing the ground on "use of non- contemporaneous data”. Then, he took permission of the Bench to argue this matter and said it is in accordance with the statutory provision that contemporaneous data should

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 7216/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2025AY 2008-09

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

Section 133(6)Section 92D

also rejected the benchmarking analysis and comparable companies selected by the Appellant without appreciating the fact that such selection was based on the 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 ... erred on facts and in law in upholding the action of the learned TPO of conducting a fresh benchmarking analysis using non contemporaneous data and substituting the Appellant's analysis with 3 ITA 6986/Mum/2011 & 7216/Mum/2012; A.Y. 2007-08 & 2008-09 Franklin Templeton International Services (India) Private Limited fresh benchmarking analysis

Franklin Templeton International Services (I) P. Ltd, Mumbai vs. Asst CIT 3(1)(OSD), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 6986/MUM/2011[2007-08]Status: DisposedITAT Mumbai13 Oct 2025AY 2007-08

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

Section 133(6)Section 92D

also rejected the benchmarking analysis and comparable companies selected by the Appellant without appreciating the fact that such selection was based on the 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 ... erred on facts and in law in upholding the action of the learned TPO of conducting a fresh benchmarking analysis using non contemporaneous data and substituting the Appellant's analysis with 3 ITA 6986/Mum/2011 & 7216/Mum/2012; A.Y. 2007-08 & 2008-09 Franklin Templeton International Services (India) Private Limited fresh benchmarking analysis

Ust Global Technology Services (India) Private Limited, Kochi vs. DCIT, Corporate Circle 2(1), Kochi

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

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate
Section 143Section 92C

erred in facts by considering the depreciation of Right to use ('RTU') of assets as operating expenses; 3 Disregarded the TP study and non-contemporaneous data used by the Ld. TPO 3.1 The Ld. AO/ Ld. TPO/Ld. Panel have erred in facts and in law, in making an addition

Ssnc Fintech Services India Private Limited, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

In the result, appeal of the Assessee is partly

ITA 916/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Jul 2025

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Ketan K. VedFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 920

erred in facts of the case and in law in disregarding the benchmarking analysis and comparable companies selected by the Appellant based on the contemporaneous data in the transfer pricing (TP) study report maintained as per section 920 of the Income Tax Act, 1961 (‘the Act') read with Rule ... Appellant. 2:4. The AO/TPO/DRP have erred in undertaking a fresh search at the time of transfer pricing assessment thereby disregarding the use of contemporaneous data and modifying/ applying additional search filters to arrive at a fresh set of alleged comparable companies to the provision of IT services rendered

Income Tax Officer-6(3)(1), Aaykar Bhawan vs. Khetalaji Gold Private Limited, Mumbai

In the result appeal of the revenue is allowed for statistical purposes

ITA 380/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jun 2025AY 2013-14

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2013-14 Income-Tax Officer 6(3)(1), Mumbai M/S. Khetalaji Gold Private Room No. 524, 5Th Floor, Aaykar Limited Bhavan, M. K. Road, Mumbai- Vs. 701, New Panchawati Chs 400020 Ltd., Tilak Vidyalaya Road, Near Parle Tilak Vidyalaya School, Vile Parle (E), Mumbai- 400057 Pan No. Aadck 6107 A Appellant Respondent

For Appellant: NoneFor Respondent: Mr. Hemanshu Joshi, CIT-DR
Section 40A(2)Section 40A(2)(a)Section 40A(2)(b)Section 92B

adjudicate the issue afresh after examining the fair market value of the purchases made from the related parties during the relevant period, based on contemporaneous data. The assessee shall be afforded adequate opportunity to present its case and file relevant evidence. The Khetalaji Gold Private Limited 8 grounds

Schindler India Private Limited, Mumbai vs. Income-Tax Officer, Mumbai

In the result, the appeal filed by the assessee is disposed off in light of aforesaid directions

ITA 4819/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai06 Jun 2025

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2020-21 Schindler India Private Limited, The Asst. Commissioner Of Schindler House, Income Tax, Main Street, Vs. Circle-15(3)(2) Hiranandani Gardens, Aayakar Bhavan, Powai, Maharshi Karve Road, Mumbai -400076 New Marine Lines, [Pan: Aaecs1548J] Churchgate, Mumbai-400020 (Appellant) (Respondent)

For Appellant: Ms. Chandani Shah a/wFor Respondent: Shri Ajay Chandra, CIT-DR
Section 143(3)Section 144CSection 144C(8)Section 270ASection 274Section 37(1)Section 92C

rejecting benchmarking approach adopted by Assessee using Comparable Uncontrolled Price method (CUP) as the Most appropriate method selected by the Assessee based on the contemporaneous data in the transfer pricing study report maintained as per section 92D of the Act read with Rule 100 of the Rules, and using 'Other

M/S Vodafone Global Services P Ltd, Pune vs. Assistant Commissioner of Income-Tax, Circle 1(1), Pune

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

ITA 660/PUN/2022[2018-19]Status: DisposedITAT Pune30 May 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.660/Pun/2022 Assessment Year : 2018-19

For Appellant: Shri Ajit Jain (Virtual)For Respondent: Shri Prakash L. Pathade
Section 143(1)Section 143(3)Section 144BSection 156Section 270Section 92C(2)Section 92D

ITeS') services 2 M/s. Vodafone Global Services Private Limited 2. Disregarding the benchmarking analysis and comparable companies selected by the Appellant based on the contemporaneous data in the transfer pricing study report maintained as per section 92D of the Act. 3. Rejecting comparable companies functionally comparable to the Appellant

Milacron India Private Limited, Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is allowed

ITA 2201/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad21 May 2025AY 2021-22

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2021-22 Milacron India Pvt.Ltd. The Dcit, Cir.2(1)(1) Plot No.93/2 & 91/4 Vs Ahmedabad. Phase-1,Gidc Vatva, Ahmedabad. Pan : Aabcc 0881 D

For Appellant: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 144C(1)Section 144C(5)Section 270ASection 92BSection 92C

receivables in any working capital”—is factually incorrect. It was contended that the working capital adjustments had been meticulously computed and substantiated with contemporaneous data, and no discrepancy or deficiency in methodology had been pointed out by the TPO. 12. The AR further submitted that the assessee had not charged ... According to the DR, this violated the cardinal principle of comparability under Rule 10B(4), which requires contemporaneous data to be used for adjustments. The DR submitted that due to this fundamental inconsistency, the working capital adjustment claimed by the assessee was distorted and the resultant computation lacked reliability, which

Jade Global Software Private Limited, Pune vs. Assessment Unit, National Faceless Assessment Centre, Pune

In the result, the Appeal of the Assessee is allowed for statistical purpose

ITA 1768/PUN/2024[2020-21]Status: DisposedITAT Pune13 May 2025AY 2020-21

Bench: Shri R.K.Panda & Shri Vinay Bhamore

For Appellant: • considering foreign exchange gain and other income as non-operating income
Section 143(3)Section 144B

length price by the TPO 3.1 The TPO erred on facts and in law in conducting a fresh benchmarking analysis using non contemporaneous data and substituting the Assessee's analysis with fresh benchmarking analysis on his own conjectures and surmises. Thus the Assessee prays that the fresh benchmarking analysis conducted

Here Solutions India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 10 (1)(1), Mumbai

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

ITA 5918/MUM/2024[2014-15]Status: DisposedITAT Mumbai08 May 2025AY 2014-15

Bench: Shrianikesh Banerjee () & Shri Girish Agrawal ()

Section 143(3)Section 144C(3)Section 250Section 92D

learned AO/TPO/CIT (A) erred on facts and in law in disregarding the benchmarking analysis conducted by the Appellant based on the contemporaneous data in the Transfer pricing study report ('TP Study Report') maintained as per Section 92D of the Income Act 1962 (the 'Act') read with Rule ... AO/TPO/ CIT (A) erred on facts and in law in disregarding the benchmarking analysis conducted by the Appellant based on the contemporaneous data in the Transfer pricing study report (TP Study Report) maintained as per section 92D of the Act read with Rule 100 of the Rules

Here Solutions India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 10 (1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 5919/MUM/2024[2013-14]Status: DisposedITAT Mumbai17 Mar 2025AY 2013-14

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Ketan VedFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(3)Section 250Section 92CSection 92D

length. 2:1 The learned AO/TPO/CIT (A) erred on facts and in disregarding the benchmarking analysis conducted by the Appellant based on the contemporaneous data in the Transfer pricing study report ('TP Study Report') maintained as per Section 92D of the Income Act 1962 (the 'Act*) read with Rule ... erred on facts and in law in disregarding the benchmarking analysis conducted by the Appellant based on the contemporaneous data in the Transfer pricing study report (TP Study Report) maintained as per section 92D of the Act read with Rule 10D of the Rules

Varian Medical Systems International (India) Private Limited, Mumbai vs. Assistant Commissioner /Dy. Commissioner of Income Tax Circle 3(3)(1), Mumbai

In the result the appeal filed by the assessee in ITA No

ITA 5086/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Feb 2025AY 2020-21

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

Section 143(3)Section 144BSection 144CSection 144C(13)Section 92D

action of the Ld. AO/TPO. 2.2 The Ld. AO/TPO erred in rejecting functional comparable companies as selected by the Assessee based on the contemporaneous data in the transfer pricing study report maintained as per section 92D of the Act read with Rule 10D of the Income-tax Rules

Varian Medical Systems International (India) Private Limited, Mumbai vs. Assistant, Deputy Commissioner of Income Tax, Mumbai

In the result the appeal filed by the assessee in ITA No

ITA 5060/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Feb 2025AY 2020-21

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

Section 143(3)Section 144BSection 144CSection 144C(13)Section 92D

action of the Ld. AO/TPO. 2.2 The Ld. AO/TPO erred in rejecting functional comparable companies as selected by the Assessee based on the contemporaneous data in the transfer pricing study report maintained as per section 92D of the Act read with Rule 10D of the Income-tax Rules

Vodafone India Services Private Limited, Mumbai vs. Income-Tax Officer, Mumbai

In the result of the appeal filed by the assessee stands partly allowed as indicated herein above

ITA 4710/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Feb 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 143Section 144BSection 144CSection 144C(8)Section 153Section 92D

international transaction pertaining to 'Provision of ITeS Services'. 2.3. The NaFAC/Ld. TPO erred in rejecting comparable companies selected by the Assessee based on the contemporaneous data in the transfer pricing study report maintained as per section 92D of the Act read with Rule 10D of the Rules, for benchmarking

Uber India Systems Private Limited (As Successor to Uber India Research and Development Private Limited), Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 581/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Jehangir D MistriFor Respondent: : Ms. M.Narmada, CIT-DR
Section 144B(1)Section 144C(13)Section 92D

further erred in upholding/confirming the action of the learned TPO of disregarding following comparable companies selected by the Appellant based on the contemporaneous data in the transfer pricing study report maintained as per Section 92D of the Act read with Rule 10D of the Rules and various submissions made

Narasimha Reddy Chimmula, Gummadidala Village vs. ACIT, Central Circle-2(4), Hyderabad

In the result, the appeals of the assessee for the A

ITA 190/HYD/2024[2021-22]Status: DisposedITAT Hyderabad05 Dec 2024AY 2021-22

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri M.V.Prasad, ARFor Respondent: Ms. Kavitha Rani, DR
Section 115BSection 271ASection 44ASection 69

earning agricultural income. Further no basis had been given by Ld.CIT(A) for restricting the agricultural income for Rs.25,000/- per acre. No contemporaneous data / comparable instance of similar agricultural activity was cited in the order. In our view, once the Ld.AO and the Ld.CIT(A) had not disputed

Narasimha Reddy Chimmula, Gummadidala Village vs. ACIT, Central Circle - 2(4), Hyderabad

In the result, the appeals of the assessee for the A

ITA 189/HYD/2024[2020-21]Status: DisposedITAT Hyderabad05 Dec 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri M.V.Prasad, ARFor Respondent: Ms. Kavitha Rani, DR
Section 115BSection 271ASection 44ASection 69

earning agricultural income. Further no basis had been given by Ld.CIT(A) for restricting the agricultural income for Rs.25,000/- per acre. No contemporaneous data / comparable instance of similar agricultural activity was cited in the order. In our view, once the Ld.AO and the Ld.CIT(A) had not disputed

Iljin Automotive Private Limited, Kanchipuram vs. DCIT Corporate Circle 2(2), Chennai

The appeal stand partly allowed in terms of our above order

ITA 1834/CHNY/2017[2013-14]Status: DisposedITAT Chennai03 Dec 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1834/Chny/2017 (िनधा)रणवष) / Assessment Year: 2013-14) M/S. Iljin Automotive Private Limited Dcit बनाम/ Plot No.B1 & B2, Sipcot Industrial Park Corporate Circle-2(2), Irungattukottai, Sriperumbudur Chennai. Vs. Kanchipuram-602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aaaci-2641-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sandeep Bagmar (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri A. Sasikumar (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 19-11-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R

For Appellant: Shri Sandeep Bagmar (Advocate) - Ld. ARFor Respondent: Shri A. Sasikumar (CIT) - Ld. DR
Section 143(3)Section 144C(5)Section 32Section 43ASection 92CSection 92C(3)

assailed rejection of usage of multiple years’ data. The same stand rejected at the outset since comparability has to be done on contemporaneous data as per extant rules. The Ld. AR seeks inclusion of M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. From the facts, it emerges that these

Imsofer Manufacturing India Pvt. Ltd., Pune vs. ACIT, Circle-12(1), New Delhi

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

ITA 7923/DEL/2019[2012-13]Status: DisposedITAT Delhi14 Nov 2024AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Reuben Mathew Jacob, Sr. DR
Section 92C(2)Section 92D

upholding/confirming the action of the Ld. TPOI AO by: 2.1 disregarding the benchmarking analysis and comparable companies selected by the Appellant based on the contemporaneous data in the transfer pricing study report maintained as per Section 92D of the Act read with Rule 10D of the Income-tax Rules ... while comparing the Appellant, being in its initial phase of operations, with already established companies. 2.7 rejecting the use of multiple year data i.e. contemporaneous data in the transfer pricing study report maintained as per Section 92D of the Act read with I Ol) of the Rules used for determining