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“aggregation of transactions”

Transfer PricingSection 92CSection 92C46 judgments

The decision most relied on for aggregation of transactions is UCB India (P) Limited v. ACIT (121 ITD 131), cited in 70 judgments on BharatTax.

Leading authorities on aggregation of transactions

UCB India (P) Limited v. ACIT
121 ITD 131 · 2009 · ITAT
70
citing judgments

For transfer pricing purposes, distinct international transactions, such as royalty payments and manufacturing, should be benchmarked separately rather than aggregated. The selection of comparables must be based on a thorough Functions, Assets, and Risks (FAR) analysis, and loss-making entities are not automatically excluded if they satisfy other comparability criteria.

Knorr-Bremse India (P) Ltd. v. ACIT
380 ITR 307 · 2016 · High Court
63
citing judgments

When transactions are part of a package deal with a composite price or are interdependent such that an assessee must accept all of them together, they must be aggregated and treated as a single international transaction for transfer pricing purposes.

CIT v. Concord Commercial Pvt. Ltd.
95 ITD 117 · 2005 · ITAT
34
citing judgments

The aggregate of business profits and losses from derivative transactions must be worked out before applying the Explanation to Section 73 of the Income-tax Act, 1961. This means that trading of shares and derivative transactions are not considered speculative transactions under Section 43(5) for the purposes of Sections 28 to 41.

Star India P. Ltd. v. ACIT
317 ITR 292 · 2009 · ITAT
16
citing judgments

When analyzing international transactions, separate classes of transactions, such as fees for technical know-how, use of trademarks, and procurement, must be analyzed individually, as each impacts profits. Aggregation of such transactions is not permissible.

Cummins India Ltd. v. Addl CIT
53 Taxmann.com 53 · 2015 · ITAT
12
citing judgments

Closely linked transactions between associated enterprises can be aggregated and treated as a single transaction for the purpose of determining the arm's length price, with the appropriate method then applied to this composite transaction.

LG Electronics Pvt Ltd. v. ACIT
22 ITR (Trib) 1 · 2013 · ITAT
11
citing judgments

The Assessing Officer may determine the arm's length price (ALP) of an international transaction, including aggregated advertising and marketing promotion (AMP) expenses, in light of the Special Bench decision in LG Electronics India Pvt. Ltd. v. ACIT.

Judgments citing 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

ITA 7487/MUM/2018[2014-15]Status: DisposedITAT Mumbai12 Feb 2026AY 2014-15

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

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Annavaram K., Sr. DR
Section 133(6)Section 144C(5)Section 92C

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

Marks and Spencer (India) Private Limited, Gurgaon vs. ACIT, Circle 1(1), Gurgaon

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

ITA 1937/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Jan 2026AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

well as permissible if the nature of transactions are closely linked. The relevant extracts from the aforesaid pronouncement are reproduced as follows: “Aggregation of transactions is desirable and not merely permissible, if the nature of transactions(s) taken as a whole is so inter-related that it will be more ... Further, in the case of Denso India limited (2016), 68 Taxamnn.com 55, Hon'ble High Court of Delhi had upheld rejection of aggregation of transactions and use of CUP by TPO for ALP determination of an International Transaction. The ration of above judgements is squarely applicable to the case

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

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

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

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

international transaction of payment for management consultancy services by considering transactional net margin method(TNMM)as the most appropriate method(MAM) and aggregating the transaction with the other international transactions like: • provision of marketing data analytical services • payment for services availed • reimbursement of remittances inadvertently credited • reimbursement of salary expenses ... principles, and that the Ld.TPO was not justified in determination of ALP at Nil. 11.1 Para 1.42 of the OECD Guidelines recognises that aggregation of transactions may be appropriate where multiple interrelated transactions form part of a composite arrangement and cannot be reliably evaluated on a standalone basis. The material

Lg Electronics India Private Limited, Mathura Road, New Delhi vs. Deputy Commissioner of Income Tax, Delhi

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

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

Lg Electronics India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Delhi

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

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

DCIT, Circle-13(1), New Delhi vs. Lg Electronics India Pvt. Ltd., Delhi

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

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

DCIT, Circle-15(2), New Delhi vs. Lg Electronics India Pvt. Ltd., New Delhi

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

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

Lg Electronics India Pvt. Ltd., New Delhi vs. DCIT, Circle-15(2), New Delhi

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

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

Lg Electronics India Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 5, New Delhi

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

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

Lg Electronics India Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 5, New Delhi

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

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

M/S Lg Electronics India Pvt. Ltd., New Delhi vs. DCIT, Noida

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

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

DCIT, Noida vs. M/S. L.G. Electronics India Pvt. Ltd., Greater Noida

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

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

Guidelines for multinational corporations and tax administrations by the Organization for Economic Co-operation and Development [OECD] which state the following on aggregation of transactions: ―3.9 Ideally, in order to arrive at the most precise approximation of arm 's length conditions, the arm's length principle should be applied

Te Connectivity India Private Limited, Bangalore vs. The Office of the Deputy Commissioner of Income-Tax, Circle 7(1)(1), Bangalore

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

ITA 2346/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Oct 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)

service segments, which are functionally interlinked. Reliance was placed on OECD Guidelines (para 3.9) and ICAI Guidance Note under section 92E which permit aggregation of transactions that are closely interrelated. The assessee also cited ITAT rulings in Toyota Kirloskar Auto Parts Pvt. Ltd. [ TS-217-ITAT-2014(Bang)] and Sony

Mylan Laboratories Limited, Hyderabad vs. ACIT, Circle-5(1), Hyderabad

In the result. appeal of the Assessee is partly

ITA 663/HYD/2022[2016-17]Status: DisposedITAT Hyderabad06 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Padamchand KhinchaFor Respondent: MS. M. Narmada, CIT-DR
Section 115JSection 92C

ITA.Nos.663 & 708/Hyd./2022 appellant company and selection of TNMM as the most appropriate method. The appellant company has also raised objection for aggregating of transactions under one basket and applying TNMM as the most appropriate method. The TPO after considering relevant submissions of appellant company and also taken note ... transactions of the appellant company with it’s AE including API segment, FDF segment, PDS segment and Injectable Formulations Segment. The TPO has aggregated the transactions of these segments with it’s AE and applied TNMM as the most appropriate method and then, compared with PLI of comparables

Toyota Boshoku Automotive India Private Limited, Bidadi vs. Assessment Unit, Income Tax Department Or the DCIT, Circle - 7(1)(1), Koramangala

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

which effectively amounted to 2.28% of net sales. The assessee benchmarked this transaction using the TNMM as the most appropriate method by aggregating all transactions. 14.1 However, the TPO separately benchmarked the royalty payment using the Profit Split Method (PSM) as the most appropriate method and made the necessary adjustment ... should not be separately benchmarked as it was part of an overall business arrangement with the AE. As such, the TPO noted that aggregation of transactions is permissible only when the underlying transactions are continuous, closely interlinked, and have a direct bearing on pricing. The burden of proving such linkage

Ariba Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

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

ITA 1587/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore07 Mar 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Mr. Aliasgar Rampurawala, C.AFor Respondent: Ms. Nandini Das, CIT (DR)
Section 143(3)Section 144C(5)Section 92C

should not be separately benchmarked as it was part of an overall business arrangement with the AE. As such the TPO noted that aggregation of transactions is permissible only when the underlying transactions are continuous, closely interlinked, and have a direct bearing on pricing. The burden of proving such linkage

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

ITA 4888/MUM/2024[2020-21]Status: DisposedITAT Mumbai27 Feb 2025AY 2020-21

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

Section 143(3)Section 144BSection 144C(13)Section 153Section 37Section 92C(1)

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

ITA 4840/MUM/2024[2020-21]Status: DisposedITAT Mumbai14 Feb 2025AY 2020-21

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

Section 143(3)Section 144C(13)Section 2Section 92B

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

Caterpillar Financial Servies India Private Limited, Whitefield, Bangalore, Karnataka vs. Assessment Unit, Income Tax Department, Jurisdictional AO - ACIT, Circle 2(2)(1)), Bmtc Building, Koramangala, Bengaluru

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

ITA 1621/BANG/2024[2020-21]Status: FixedITAT Bangalore04 Feb 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Sridhar E, CIT (DR)
Section 92C

No.1621/Bang/2024 Page 13 of 14 18.1 While determining the Arm’s Length Price (ALP) of international transactions under transfer pricing regulations, aggregation of transactions is often necessary provided transactions are closely linked functionally or economically. Likewise, transactions of similar type (e.g., sale of goods, services, intangibles) can be aggregated

Assistant Commissioner of Income Tax Circle 2(1) (1) Ahmedabad, Vejalpur Ahmedabad vs. Inductotherm (India) Private Limited, Ahmedabad

Appeal are dismissed

ITA 598/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Oct 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Ms. Chandni Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 143(2)Section 143(3)Section 144C(3)Section 14ASection 195Section 40Section 92C

Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in allowing aggregation of transaction which is contrary to the provisions of section 92C and Rule 10A to 10C of Income Tax Rules? 4. Whether on facts and in the circumstances ... assessee, which was upheld by the CIT(A) but contested by the AO and TPO. The assessee, in its transfer pricing study, aggregated its transactions and adopted TNMM on an entity-wide basis, justifying that it was the most appropriate method for benchmarking its international transactions due to the volume