“related party transaction”

DisallowancesSection 40A(2)(b)Section 40A(2)(b)490 judgments

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

ITA 6104/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Mar 2026AY 2012-13

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

Section 143(3)

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

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Section 143(1)Section 143(3)Section 263Section 40A(2)

Revenue.\n\n2.1 In the aforesaid notice, the Principal CIT made a detailed observation with regard to issues relating to (i) Related Party Transactions, (ii) Platform Selling Expenses, (iii) Provision for Doubtful Advances, (iv) Aging Goods, (v) Changes in liability arising from financing activities, (vi) Trade Payables, (vii) Purchase ... response to the show-cause notice issued under section 263 of the Act, the learned PCIT dealt with the following issues:\n\ni. Related Party Transactions, the learned PCIT reproduced the submissions made by the assessee at pages 24 to 26 of the impugned order and observed that the Assessing

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 5560/DEL/2024[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(1)Section 143(1)(a)Section 143(3)Section 80Section 80ISection 92C

reflect the statutory prescription as contained in section 92C read with Rule 10C. Under the statutory provision, under the CUP method, the related party transactions are required to be compared with the unrelated third-party transaction. While as submitted, the tariff rates are generally prescribed rates rather than instance

PLASCOM INDUSTRIES LLP,KOLKATA vs. THE INCOME TAX OFFICER, WARD-1(3), GUWAHATI

In the result, appeal of the assessee is allowed

ITA 280/GTY/2025[2023-24]Status: DisposedITAT Guwahati02 Mar 2026AY 2023-24

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: S.M. Surana, AdvocateFor Respondent: Sanjay Jha, JCIT

Section 133(6)Section 142(1)Section 250Section 801ESection 801E(3)Section 801E(4)Section 801E(5)Section 801E(6)Section 80I

declaring total income at Rs. 3,69,890/-. The case was selected for scrutiny under CASS for the following reasons: (i) High related party transactions and undertaking claiming deduction u/s 80IA/80IC etc. 3. Accordingly, notice was issued to the assessee. Subsequently, other statutory notices were issued to the assessee ... Rs.2,44,02,080/- should not be disallowed as over valuation of sales and undervaluation of purchase from related parties transactions and reduced from the claim for deduction u/s.801E of the IT Act and taxed as regular income as per provisions of section 801E(6) r.w.s. 801A

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

ITA 5324/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Feb 2026AY 2011-12

Section 143(1)Section 143(3)Section 254Section 40A(2)(b)Section 68

comparison becomes incomplete unless the\ncapitalised components are also brought into the\nreconciliation. The assessee has precisely done that by\nproducing the related party transaction schedule and the\nreconciliation. The reconciliation is not a mere oral claim; it is\na structured working supported by audited disclosures,\nshowing that the total

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

ITA 5323/MUM/2025[2012-13]Status: DisposedITAT Mumbai24 Feb 2026AY 2012-13

Section 143(1)Section 143(3)Section 254Section 40A(2)(b)Section 68

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16

Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

accounting year other\nthan March 31 or companies whose financial statements were\nfor a period other than 12 months);\nb) Applying incorrect modified related party transaction (\"RPT\")\nfilter to reject companies, which included application of the\nfollowing filters separately:\nAn RPT filter for the revenue transactions only (RPT\nrevenue greater ... companies whose\nSoftware Development Service income was less than 75% of its total\noperating revenues (e) excluded companies which have more than\n25% related party transactions (f) excluded companies which had\nexport service income of less than 75% of the sales (g) excluded\ncompanies with employee cost less than

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,DELHI-8, JHANDEWALAN EXTENSION, NEW DELHI vs. POOJA MITTAL, DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1336/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Feb 2026AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganeshassessment Year 2014-15 Dcit Vs. Pooja Mittal B-33, Defece Central Circle Colony, Delhi-110024 Delhi Pan No. Ahapm5624K Appellant Respondent Appellant Sh. Om Prakash, Sr. Dr Respondent Sh. Akshat Jain, Ca Sh. Rajat Jain, Ca

Section 133ASection 147Section 148Section 69A

Navneet Dawar, Sh. Anil Narang ( Proprietor of M/s. Unique Associates) and Sh. Gurvinder Duggal and the said search and seizure operation many related party transaction were found and proceedings u/s.133A of the Act were initiated on various assesses. Accordingly, a survey operation u/s. 133A was carried out at the premises ... Navneet Dawar, Sh. Anil Narang ( Proprietor of M/s. Unique Associates) and Sh. Gurvinder Duggal and the said search and seizure operation many related party transaction were found and proceedings u/s.133A of the Act were initiated on various assesses. Accordingly, a survey operation u/s. 133A was carried out at the premises

ACIT, MUMBAI vs. DNJ CREATION LLP, MUMBAI

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

ITA 4329/MUM/2025[2017]Status: DisposedITAT Mumbai13 Feb 2026

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

Section 10ASection 143(3)Section 254(1)Section 92C

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

ITA 4157/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

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

Section 143(3)Section 144C(13)Section 144C(5)Section 254

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

ITA 4156/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

Section 143(3)Section 144C(13)Section 144C(5)Section 254

nreport. For Assessment Year 2015–16, all eleven companies\nselected by the assessee were rejected on various grounds,\nincluding application of turnover filter, related party transaction\nfilter, export filter and alleged functional dissimilarity. For\n Assessment Year 2016–17, all seventeen companies selected by\nthe assessee were similarly rejected ... nthe comparables selected by the assessee. Detailed reasons have\nbeen recorded for rejection of each comparable on grounds such\nas turnover filter, related party transaction filter, export filter and\nfunctional dissimilarity. The DRP has also examined and affirmed\nthese findings. Therefore, to the extent of examination of\ncomparables, it cannot

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)

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

ITA 7300/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Feb 2026AY 2015-16

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)

Section 147Section 147oSection 148Section 148ASection 151A

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

ITA 7299/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Feb 2026AY 2014-15

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)

Section 147Section 147oSection 148Section 148ASection 151A

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

In the result, all the above appeals in ITA Nos

ITA 7298/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14

Section 147Section 148Section 148ASection 151A

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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I NOIDA, NOIDA vs. M/S IT ENFRASERVICES PRIVATE LIMITED, NOIDA

In the result, Appeal of the Revenue is dismissed

ITA 5961/DEL/2025[2023-24]Status: DisposedITAT Delhi11 Feb 2026AY 2023-24

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaydy. Commissioner Of Income Vs M./S It Enfraservices Private Tax, Central Circle-1 A.R.T.O Limited. 7Th Floor, Tower-C, Complex, Sector-33 Noida Bhutani Alphatum, Janpath Marg, Sector-90, Noida, Uttar Pradesh Pan: Aabci0514K Appellant Respondent Assessee By Sh. Rohit Kapoor, Adv & Sh. Ashok Pandit, Adv Revenue By Sh. Mahesh Kumar, Cit Dr Date Of Hearing 04/02/2026 Date Of Pronouncement 11/02/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of Ld.

Section 132Section 143(3)Section 68

above table it appears that the AO failed to take into account the amounts mentioned at S. No. 3 and 6 of the related party transactions which are in respect of amounts which have been paid by the respective parties i.e. M/s. Goodliving Infrastructure Pvt. Ltd. and M/s. Parmesh Construction ... unsecured loans. From the discussion carried out above, it is apparent that the AO has missed out on including the value of related party transactions i.e. the reimbursement to be made to Parmesh Construction Company Limited and Goodliving Infrastructure Pvt. Ltd. amounting

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

ITA 5704/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Jagadish

Section 143(3)Section 250Section 68

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

FIBERHOME INDIA (P) LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

Appeal of the assessee is partly allowed

ITA 6083/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Jan 2026AY 2021-22

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2021-22

Section 14Section 143(3)Section 144BSection 144C(5)Section 92C

Assessee company. The Assessee submitted that these companies were rejected for the selection because they either had insufficient description information, or significant related party transaction or had exceptional year of operation. The reasons were not considered by the AO and he rejected the submission in a summary manner

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1357/PUN/2025[2020-21]Status: DisposedITAT Pune28 Jan 2026AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR

Section 11Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 2(15)Section 263

parties is very miniscule compared to the assessee trust. He therefore was of the opinion that this unusual high profit margin in a related party transaction suggests that the payments made to VGSPL were disproportionately high leading to the conclusion that the transactions lack commercial prudence and were designed

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Section 143(3)Section 43(1)

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n'D' BENCH, CHENNAI\nBEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND

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