“aggregation of transactions”

AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD.,MUMBAI vs. DCIT (IT)-1(1)(2), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2014-15 Australia & New Zealand Deputy Commissioner Of Banking Group Ltd. Income-Tax – 1(1)(2), Unit A, Sixth Floor, Mumbai Cnergy Centre, Appasaheb Marathe Marg, Vs. Prabhadevi, Mumbai – 400 025 (Pan : Aaica3008P) (Appellant) (Respondent) Present For: Assessee : Shri Madhur Agrawal, 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 The Dispute Resolution Panel-1, Mumbai, (Drp) Vide Order Dated 04.09.2018 U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground 1: Determination Of The Arm'S Length Price (Alp) Of The International Transaction Relating To Processing Fees Received On Account Of Guarantees Issued To Indian Companies Based On Counter-Guarantee From Overseas Branches

Whether on the facts and circumstances of the case and in law, the CIT(A) has erred in directing the AO/TPO to aggregate the transactions and thereby directing to delete the adjustment/addition of Rs. 80,45,571/-in a case where the ALP of each transaction could be arrived ... order. Aggrieved, assessee preferred the appeal before CIT(A), who is deleted the addition by stating that the assessee has rightly aggregating the transactions of all the parties and then reached to proper LIBOR rate. The CIT(A) deleted the addition by observing in para 7.3 to 7.5 as under

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

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

UPS EXPRESS PRIVATE LIMITED,MUMBAI vs. DEPUTY C/ASSISTANT COMMISSIONER OF INCOME TAX 3(1)(1), MUMBAI

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

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

reimbursement of expenses (received) of ₹ 2,32,47,077/- to the operating revenues as well as the operating costs for the purpose of aggregation of transactions and determining arm's length price under TNMM. Further, the TPO observed that the reimbursement of expenses pertaining to each segment is not available

VVF (INDIA) LIMITED,MUMBAI vs. INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE , MUMBAI

In the result appeal filed by the assessee stands partly allowed for statistical purposes

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

2.3.That the DRP/NFAC/AO/TPO erred on facts and in law in benchmarking international transactions by comparing Assessee's entity level margin arrived at by aggregating AE transactions and non-AE transactions with the margin of companies not comparable with the Assessee company. 2.4.That the DRIP/NFAC/AO/TPO erred on facts ... hands of the assessee. Aggrieved by the draft assessment order, the filed objections before DRP. 4. DRP upheld the action of aggregating international transactions by the Ld.TPO. The DRP also upheld comparables selected by the Ld.TPO, without analyzing the functional similarities. 4.1. The corporate guarantee commission attributed by the Ld.TPO