“related party transaction”

REGUS SOUTH MUMBAI BUSINESS CENTRE PVT. LTD.,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 14(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarregus South Mumbai Dcit - 14(1)(2), Business Centre Mumbai Private Limited, Vs. Aayakar Bhavan, M. Level 4, Dynasty K. Road, New Marine Business Park, Andheri Lines. Mumbai- Kurla Road, J. B. Nagar 400 020 S.O, Mumbai – 400 059 Pan/Gir No. Aadcr6068H (Applicant) (Respondent) Assessee By Shri Ketan Ved, Ld. Ar Revenue By Smt. Usha Gaikwad, Ld. Dr Date Of Hearing 16.03.2026 Date Of Pronouncement 26.03.2026

factually incorrect, as the same have been duly accounted for and disclosed in the notes to accounts under the head “other expenses” and “related party transactions”. It was further submitted that similar disclosures have also been made in the financial statements of the group entity incurring such expenditure. 12. With

EQUIFAX CREDIT INFORMATION SERVICES PVT LTD,MUMBAI vs. INCOME TAX OFFICER WD-9(2)(1), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

EQUIFAX CREDIT INFORMATION SERVICES PVT LTD,MUMBAI vs. INCOME TAX OFFICER WD-9(2)(1), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

ACIT, MUMBAI vs. DNJ CREATION LLP, MUMBAI

In the result, grounds of appeal raised by revenue are dismissed

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing)

section 80-IA(8) and 80IA(10) would submit that the plain reading of the provisions clearly suggests that where inter-unit or related party transactions resulted in inflated profit of an eligible undertaking, the statue mandates a fresh computation of profit solely for the purpose of deduction. The adjustment

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

report. For Assessment Year 2015–16, all eleven companies selected by the assessee were rejected on various grounds, including application of turnover filter, related party transaction filter, export filter and alleged functional dissimilarity. For Assessment Year 2016–17, all seventeen companies selected by the assessee were similarly rejected. The TPOtook ... rejected the fresh comparables as well. The DRP, in its directions under section 144C(5), upheld the application of turnover, related party transaction and export filters and agreed with the TPOthat no appropriate comparable companies were available for application of External TNMM. The DRP further held that the remand

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

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER& SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT

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:

limited. 7.2. Assessee raised other two aspects also in respect of Ivycap by submitting that it has high percentage of related party transactions which comes to 26%, higher than the 25% filter applied by ld. TPO. Details in this respect is tabulated below: Calculation of related party transaction ... final list of comparables has a different operating model when compared with the assessee both on account of related party transactions and high percentage of outsourcing expenses. The third aspect of high margin remains uncontroverted. It is also undisputed that the two aspects relating to RPT filter and high percentage

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

movement of funds without having any actual trade as no supporting documents had been submitted in support of this transaction. Most of the related party transactions were between the 18 parties which were controlled by one Sharon Bio Medicine Limited(SBML) and assessee was one of such parties with whom

IMPRESSIVE TRADING PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

In the result, all the above appeals in ITA Nos

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

movement of funds without having any actual trade as no supporting documents had been submitted in support of this transaction. Most of the related party transactions were between the 18 parties which were controlled by one Sharon Bio Medicine Limited(SBML) and assessee was one of such parties with whom

IMPRESSIVE TRADING PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER 10(1)(1), MUMBAI

movement of funds without having any actual trade as no supporting documents had been submitted in support of this transaction. Most of the related party transactions were between the 18 parties which were controlled by one Sharon Bio Medicine Limited(SBML) and assessee was one of such parties with whom

DCIT CIRCLE 2.3.1, MUMBAI, MUMBAI vs. STG REFRACTORY SERVICES PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Saktijit Dey & Shri Jagadish

earlier year. In the absence of such a finding, reimbursement does not assume the character of income. Mere disclosure of the transactions as related party transactions in the audit report does not alter their tax character. The deletion of the addition is thus in accordance with law. 10. In view