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“arm's length price”

Transfer PricingSection 92Section 921,810 judgments

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

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

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

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

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

specified domestic transaction of transfer of steam by eligible power unit to non-eligible unit [at its cost of production] by treating its arm's length price /cost of production at NIL on wholly erroneous, superficial and arbitrary grounds. 6. That the Ld. DRP/TPO and consequently the Ld. AO have ... That the Id. TPO and consequently the Ld. AO have erred in not entertaining the submissions of assessee to re-determine the arm's length price of steam transferred from eligible unit to non eligible units at ₹4,57,73,00,068/- [instead at its cost of production

DCIT, NEW DELHI vs. M/S. ARKADIN CONFER INDIA PVT. LTD., NOIDA

In the result, the appeal of the Revenue in ITA No:- 6037/Del/2015

ITA 6037/DEL/2015[2011-12]Status: DisposedITAT Delhi18 Mar 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Dharm Veer Singh, CIT(DR)
Section 143(3)Section 254(2)

Revenue’s appeal is the deletion of an amount of Rs. 7,05,54,285/- on account of adjustment to the Arm’s Length Price (ALP). The ld DR explained that the Revenue had filed a Miscellaneous Application u/s 254(2) of the IT Act, 1961 arising ... Supreme Court was that where the international transaction was above Rs.5 crores, same should have been referred to Id. TPO for determination of arm's length price of the international transaction and the Tribunal ought to have restored the issue to the file of AO, so that appropriate reference could

JUBILANT INGREVIA LIMITED,BHARTIAGRAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, MORADABAD

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

ITA 5851/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanjubilant Ingrevia Ltd, Vs. Acit-1, Bhartiagram Bhartia Gram, So Moradabad, Up Dhanaura, Jyotiba Phule Nagar, Uttar Pradesh (Appellant) (Respondent) Pan: Aaecj6722D

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Jitendra Singh, CIT DR
Section 115Section 143(1)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 154Section 234ASection 234CSection 270A

case of the assessee was referred to Learned Transfer Basing Officer (TPO) under section 92CA(1) of the Act to determine the arm's length price of the international transactions undertaken by the assessee. The Learned TPO passed an order under section 92CA(3) of the Act dated

DY.COMMISSIONER OF INCOME TAX, MUMBAI vs. BP INDIA PVT LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 143(3)

circumstances of the case and in law, the ld. Transfer Pricing Officer ('ld. TPO)/ Assessing Officer ('AO') made a TP adjustment to the arm's length price ('ALP') of the assessee's international transaction. While making the TP adjustment, the ld. TPO/AO erred in: 1.1. rejecting the economic analysis undertaken ... selecting the comparables and applying certain additional filters. 1.3. including certain functionally dissimilar companies in the final set of comparables for computing the arm's length price. 1.4. excluding certain functionally similar companies in the final set of comparables for computing the arm's length price. 1.5. disregarding the provisions

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

In the result, the appeal filed by the Revenue is dismissed,\nwhereas the appeal filed by the assessee is partly allowed

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20
Section 135Section 143(3)Section 144BSection 14ASection 250Section 80GSection 80JSection 92C

nTransfer Pricing Officer under section 92CA of the Act on\n16.07.202, who passed an order dated 27.01.2022 without\nproposing any adjustment to the arm's length price.\n3. The assessment was completed under section 143(3) read\nwith section 144B of the Act vide order dated 27.09.2022. During\nthe course

FIRSTRAND BANK LIMITED - INDIA BRANCH,MUMBAI vs. ASSISTANT COMMISSIONER , MUMBAI

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 133(6)Section 144C(5)Section 92C

made to ld. TPO against which order u/s.92CA(3) was received by the ld. Assessing Officer, proposing an upward adjustment for the arm's length price (ALP) of the international transaction entered into by the assessee, detail of which is tabulated below: Nature of transaction Adjustment Amount (Rs.) Guarantee commission

CA (INDIA) TECHNOLOGIES P.LTD,MUMBAI vs. ITO RG 14(1)(4), MUMBAI

In the result, the appeal is dismissed

ITA 7381/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey, Vp & Shri Makarand Vasant Mahadeokar, Am Ca (India) Technologies Private The Income Tax Officer-14(1)(4) Limited Room No. 458, Aayakar Bhavan, Ground Floor, Vibgyor Tower, Mumbai-400 020 Plot C-62, G-Block, Vs. Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Aaacc 4971 D (Appellant) : (Respondent) Appellant By : None Respondent By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 06.03.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Makarand V. Mahadeokar, Am: This Is An Appeal By The Assessee Against Order Dated 18.09.2018 Of First Appellate Authority, Pertaining To Assessment Year (A.Y.) 2014-15. 2. The Assessee Vide Letter Dated 26.02.2026 Has Submitted That The Dispute Has Been Resolved Through Mutual Agreement Procedure (“Map”) & The Assessee Has Accepted The Map Resolution, Hence, Request Has Been Made For Withdrawal Of The Appeal. The Contents Of The Said Letter Are As Under: Dear Sir, Re: Ca (India) Technologies Private Limited ('Ca India' Or 'Appellant') Permanent Account Number ('Pan'): Aaacc4971D Assessment Year ('Ay'): 2014-15 Appeal No. Ita 7381/Mum/2018

For Appellant: NoneFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C

this adjustment. Further, the Appellant is of the view that the acceptance of MAP resolution should not have any effect on the arm's length price to be determined for on-going litigation for other years. 7. Accordingly, the Appellant humbly communicates its acceptance of MAP resolution as per Rule

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1223/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Feb 2026AY 2017-18
For Respondent: \nShri P. Murali Mohan Rao, CA
Section 132Section 144C(13)Section 148Section 153BSection 153CSection 69

issued on 24.2.2021, a fact not\ndisputed by the Revenue. There is no reference made to the\nTPO for making any adjustment of arm's length price of the\ninternational taxation. We find the provisions of section 153(2)\nread as under:\n\"153. Time limit for completion of assessment

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

from the Assessing Officer (AO), Transfer Pricing Officer (TPO) examined the said transaction and issued a show cause notice proposing to determine the arm's length price (ALP) of the royalty payment at NIL. Assessee submitted a detailed reply in support of the transaction, however, Ld. TPO proceeded to determine ... royalty by applying any of the prescribed methods provided under the statute. Without assigning any reason, the Transfer Pricing Officer has determined the arm's length price of the royalty payment at nil. Prima-facie, it appears, the determination of arm's length price of royalty payment

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

from the Assessing Officer (AO), Transfer Pricing Officer (TPO) examined the said transaction and issued a show cause notice proposing to determine the arm's length price (ALP) of the royalty payment at NIL. Assessee submitted a detailed reply in support of the transaction, however, Ld. TPO proceeded to determine ... royalty by applying any of the prescribed methods provided under the statute. Without assigning any reason, the Transfer Pricing Officer has determined the arm's length price of the royalty payment at nil. Prima-facie, it appears, the determination of arm's length price of royalty payment

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22
For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)
Section 143(3)

service provider.\n6.4 It was accordingly prayed that such functionally dissimilar\ncompanies be excluded from the final list of comparables while\ndetermining the arm's length price of the international transactions\nrelating to software development services.\n6.5 The Ld. DRP, while dealing with the assessee's contention that\nhigh-turnover

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

Section 144C(5) of the Act. 2. The Assessee has raised following grounds of appeal : “1. Ground No. 1: In re-computing the arm's length price ("ALP") for the international transaction relating to payment of interest on External Commercial Borrowings IT(TP)A No.2525/Bang/2024 Assessment Year 2021-2022 ("ECBs ... selected for scrutiny. During the assessment proceedings reference was made to the Transfer Pricing Officer (for short ‘the TPO’) for determination of Arm’s Length Price (ALP) of the international transactions entered into by the Assessee with its Associated Enterprises (AEs) during the relevant previous year. The TPO passed Order

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)

erred in making addition of INR 1,040,059,562 to\ntotal income of Appellant on pretext that price charged was lower\nthan arm's length price determined for software development\nservices rendered by the Appellant to its AEs and outstanding\nreceivables thereon;\n3\nLd. AO/TPO pursuant to the directions ... nAssociated Enterprises (AEs) and therefore, a reference was made\nunder Section 92CA(1) to the Transfer Pricing Officer (TPO) for the\ndetermination of Arm's Length Price (ALP) of the international\ntransactions. The TPO noted that as per the Transfer Pricing (TP)\ndocuments furnished for the Assessment Year

DCIT 2(3)(2), MUMBAI vs. ICICI BANK LTD, MUMBAI

ITA 1560/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

vide his\norder dated January 23, 2014 passed under section 92CA(3) of the Act and\nconfirming the adjustment made to the arm's length price in respect of back\noffice support services.\n2. Expenses apportioned against income exempted under section 10(15),\n10(34) and 10(35)-\nDisallowance

ICICI BANK LTD,MUMBAI vs. DCIT 2(3)(2), MUMBAI

Appeal is partly allowed

ITA 1446/MUM/2016[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 10(15)Section 143(3)Section 14ASection 92B(1)Section 92C

vide his\norder dated January 23, 2014 passed under section 92CA(3) of the Act and\nconfirming the adjustment made to the arm's length price in respect of back\noffice support services.\n2. Expenses apportioned against income exempted under section 10(15),\n10(34) and 10(35)\nDisallowance

DCIT-13(1)(1), MUMBAI vs. M/S ORACLE FINANCIAL SERVICES SOFTWARE LTD., MUMBAI

In the result, appeal of the revenue stands partly allowed and\nappeal of the assessee stands allowed

ITA 3995/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09
Section 14A

value of international\ntransaction as recorded in the books of accounts and determining a new\narm's length price in substitution of the arm's length price determined by the\nAppellant.\n3.2 On facts of the case and in law, the CIT(A) erred and violated the\nprinciple of natural ... transactions with its Associate Enterprise [AE]\nexceeding the threshold limit. Reference was, therefore, made to the\nTransfer Pricing Officer [TPO] to determine the Arm's Length price\n[ALP] of the transactions. The Ld. TPO, upon receipt of the reference,\ncalled upon the assessee to furnish economic details

ORACLE FINANCIAL SERVICES SOFTWARE LIMITED,MUMBAI vs. ACIT-13(1)(1), MUMBAI

In the result, appeal of the revenue stands partly allowed and\nappeal of the assessee stands allowed

ITA 3432/MUM/2019[2008-09]Status: DisposedITAT Mumbai19 Feb 2026AY 2008-09
Section 14A

value of international\ntransaction as recorded in the books of accounts and determining a new\narm's length price in substitution of the arm's length price determined by the\nAppellant.\n3.2 On facts of the case and in law, the CIT(A) erred and violated the\nprinciple of natural ... transactions with its Associate Enterprise [AE]\nexceeding the threshold limit. Reference was, therefore, made to the\nTransfer Pricing Officer [TPO] to determine the Arm's Length price\n[ALP] of the transactions. The Ld. TPO, upon receipt of the reference,\ncalled upon the assessee to furnish economic details

M/S. ALKRAF THERMOTECHNOLOGIES PVT. LTD.,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeals of the assessee for AYs 2011-12, 2012-\n13, 2013-14, 2017-18 & 2018-19 are allowed\nOrder pronounced on the 18th day of February, 2026, in Chennai

ITA 1949/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Feb 2026AY 2017-18
Section 80

evidence brought on\nrecord by the AO which would show that, the radiators and inter-coolers\nwere not being procured at arm's length price by the UTK Unit. Hence, we\nare unable to countenance this line of reasoning propounded by the lower\nauthorities.\n32. In view of the above

DCIT, KOLKATA vs. HIMADRI SPECIALITY CHEMICAL LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2223/KOL/2025[2012-13]Status: DisposedITAT Kolkata17 Feb 2026AY 2012-13
Section 115JSection 92C

hearing.\n3. The issue raised in ground no.1 to 4 and 8 is against the order of Id. CIT (A) deleting the Arm's Length Price adjustment of ₹3,97,99,637 as made by the Id. AO/Transfer Pricing Officer on account interest on loan.\n3.1. The facts in brief ... associated enterprise M/s Himadri Global Industries Ltd. (HGIL) and accordingly, the matter was referred to the Id. Transfer Pricing Officer for determining the Arm's Length Price (ALP), who computed the adjustment of interest component charged by the assessee company by making upper adjudgment on account of interest on loan

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA vs. M/S SCHAEFFLER INDIA LTD, VADODARA

ITA 2036/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2009-10

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 92C

observe that ITAT Ahmedabad in assessee's own case for AY 2002-03 has held that TNMM may be used for determination of Arm's Length Price for Royalty payments The relevant extracts of the order passed by ITAT Ahmedabad in assessee’s own case ... remand proceedings have given a specific findings that if TNMM has taken to be the most appropriate method, the transactions is at Arm's Length Price (refer Para 3.6.1.. Page 21 of CIT(A) for AY 2010-11) Accordingly, in view of the decision of ITAT Ahmedabad in assessee

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