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“arm's length price”

Transfer PricingSection 92Section 921,810 judgments

The decision most relied on for arm's length price is CIT v. EKL Appliances Ltd. (345 ITR 241), cited in 422 judgments on BharatTax.

Leading authorities on arm's length price

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

CIT v. Everest Kento Cylinders Ltd.
378 ITR 57 · 2015 · High Court
304
citing judgments

Corporate guarantee fees are subject to transfer pricing rules, and adjustments may be needed to account for differences between corporate guarantees and more liquid bank guarantees when determining arm's length price.

Maruti Suzuki India Ltd. v. CIT
381 ITR 117 · 2016 · High Court
220
citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Chryscapital Investment Advisors (India) Pvt. Ltd. v. DCIT
376 ITR 183 · 2015 · High Court
170
citing judgments

For transfer pricing comparability analysis, companies should not be excluded solely based on higher turnover if they are otherwise functionally comparable, unless the turnover difference reflects fundamental functional dissimilarities, brand value, or risk profiles that materially impact profitability.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT
381 ITR 227 · 2016 · High Court
127
citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

CIT v. Cushman & Wakefield (India) (P.) Ltd.
367 ITR 730 · 2014 · High Court
120
citing judgments

This case determines the Arm's Length Price (ALP) for intra-group services and reimbursements, clarifying when charges constitute services warranting a mark-up versus mere pass-through costs. It provides guidance on the circumstances under which an ALP adjustment, including an ALP of 'nil', is appropriate for such transactions.

CIT v. Tata Autocomp Systems Ltd.
56 Taxmann.com 206 · 2015 · High Court
119
citing judgments

When determining the arm's length price for interest on a foreign currency loan advanced to an Associated Enterprise, the Indian Prime Lending Rate is not applicable. Instead, the interest rate should be benchmarked based on the prevailing foreign currency rate, such as EURIBOR, or the rate in the country where the loan is received/consumed.

Judgments citing arm's length price

The India Cements Limited, Chennai vs. DCIT Corporate Circle 2(1) Chennai, Chennai

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

ITA 2174/CHNY/2024[2017-18]Status: DisposedITAT Chennai02 Jan 2026AY 2017-18
Section 10(39)Section 115JSection 14A

Vishnupuram WHRP. During the course of assessment proceedings, the AO referred the matter of computation of arm's length price of power units transferred to manufacturing units to the TPO. The TPO in the assessment framed u/s 92CA(3) of the Act did not agree with the benchmarking exercise adopted

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

case and in law, the Hon'ble DRP and learned DCIT erred in confirming the learned TPO's action of determining the arm's length price of the appellant's international transaction of reimbursement of expenses (in the nature of employee expenses, inter- connectivity charges, SAP related cost, professional expenses ... been prescribed as one of the methods under Rule 10B(1)(b) of the Income Tax Rules ("the Rules") for the determination of arm's length price under section 92C of the Act. Rule 10B(1)(b) of the Rules reads as follows: - "Section 10B(1)(b) in Income

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

case and in law, the Hon'ble DRP and learned DCIT erred in confirming the learned TPO's action of determining the arm's length price of the appellant's international transaction of reimbursement of expenses (in the nature of employee expenses, inter- connectivity charges, SAP related cost, professional expenses ... been prescribed as one of the methods under Rule 10B(1)(b) of the Income Tax Rules ("the Rules”) for the determination of arm's length price under section 92C of the Act. Rule 10B(1)(b) of the Rules reads as follows: - “Section 10B(1)(b) in Income

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

case and in law, the Hon'ble DRP and learned DCIT erred in confirming the learned TPO's action of determining the arm's length price of the appellant's international transaction of reimbursement of expenses (in the nature of employee expenses, inter- connectivity charges, SAP related cost, professional expenses ... been prescribed as one of the methods under Rule 10B(1)(b) of the Income Tax Rules ("the Rules") for the determination of arm's length price under section 92C of the Act. Rule 10B(1)(b) of the Rules reads as follows: - "Section 10B(1)(b) in Income

Thermo Fisher Scienftific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

case and in law, the Hon'ble DRP and learned DCIT erred in confirming the learned TPO's action of determining the arm's length price of the appellant's international transaction of reimbursement of expenses (in the nature of employee expenses, inter- connectivity charges, SAP related cost, professional expenses ... been prescribed as one of the methods under Rule 10B(1)(b) of the Income Tax Rules ("the Rules”) for the determination of arm's length price under section 92C of the Act. Rule 10B(1)(b) of the Rules reads as follows: - “Section 10B(1)(b) in Income

Oracle Systems Corporation, New Delhi vs. DDIT, New Delhi

In the result, assessee’s appeals in :

ITA 3313/DEL/2013[2005-06]Status: DisposedITAT Delhi02 Jan 2026AY 2005-06

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable and is applicable

Oracle Systems Corporation, New Delhi vs. ADIT, New Delhi

In the result, assessee’s appeals in :

ITA 1836/DEL/2009[2004-05]Status: DisposedITAT Delhi02 Jan 2026AY 2004-05

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable and is applicable

Oracle Systems Corporation, New Delhi vs. ADIT, New Delhi

In the result, assessee’s appeals in :

ITA 1835/DEL/2009[2003-04]Status: DisposedITAT Delhi02 Jan 2026AY 2003-04

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable and is applicable

Oracle Systems Corporation, New Delhi vs. ADIT, New Delhi

In the result, assessee’s appeals in :

ITA 1834/DEL/2009[2002-03]Status: DisposedITAT Delhi02 Jan 2026AY 2002-03

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable and is applicable

Oracle Systems Corporation, New Delhi vs. ADIT, New Delhi

In the result, assessee’s appeals in :

ITA 1833/DEL/2009[2001-02]Status: DisposedITAT Delhi02 Jan 2026AY 2001-02

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Indruj Sngh Rai, Spl. Counsel
Section 234ASection 250(1)(a)Section 9(1)(vi)

Corpn. Vs. ADDCIT in India and warrants further profits attribution in the hands of the assessee. • Cost Plus Method does not give correct arm's length price in transactions of intangibles and that the correct method is 'Profit Split Method". • Partial force of attraction is operable and is applicable

Dy Commissioner of Income Tax, Mumbai vs. Bp India Pvt Ltd, Mumbai

In the result, the grounds of appeal raised by Revenue are

ITA 4873/MUM/2025[2012-13]Status: DisposedITAT Mumbai31 Dec 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2012-13 (Physical Hearing) Dy. Commissioner Of Income Tax, Bp India Pvt. Ltd. Room No.535, Aayakar Bhavan, Pb No. 19411, Technopolis Vs. Mumbai – 400020. Knowledge Park, Andheri, Mumbai- 400043. Pan No. – Aaccb2020Q (Appellant) (Respondent) C.O. No. 277/M/2025 In Ita No.4873/M/2025 Assessment Year: 2012-13

For Appellant: Ms. Chandni Shah/ Mr. AmolFor Respondent: Shri Bhagirath Ramawat (SR. D.R.)
Section 234DSection 271(1)(c)

circumstances of the case and in law, the Learned 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

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

illegal, unsustainable and ought to be deleted, as the learned AO/Id. TPO has not applied any of the methods for determination of arm's length price as prescribed under section 92C of the Act, read with rule 100 of the rules being the most appropriate method. 3. On the facts ... learned AO/TPO erred and the Hon'ble DRP further erred in upholding/confirming the action of the learned AO/TPO in determining the arm's length price of the international transactions relating to Payment of License Fees / Royalty, payment of management recharge cost and payment of IT support and SAP systems recharge

Luxottica India Eyewear Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

Appeal of the assessee is allowed for statistical purposes

ITA 1492/DEL/2015[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Manish Agarwalluxottica India Eyewear Pvt. Ltd., Asst. Cit, 7Th Floor, Dlf Building No.9, Circle-15(2), Tower-B, Phase-Iii, Dlf Cyber Vs. New Delhi. City, Gurgaon-122002, Haryana. Pan-Aabcl3871C (Appellant) (Respondent) Assessee By Ms. Tanmayee Rajkumar, Adv., Ca Department By Shri Dheeraj Kumar Jaiswal, Sr. Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 31.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 30.01.2015 Passed U/S 143(3) R.W.S.144C(1) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) In Compliance To The Direction Given By Ld. Dispute Resolution Panel (Drp) Vide Order Dated 15.12.2014 For Asst. Year 2010-11. 2. In The Present Appeal, The Co-Ordinate Bench Vide Order Dated 26.05.2017 In Ita No.1492/Del/2015 Has Remand The Issue Of Tp Adjustment Towards Alleged Amp Expenses To The File Of Tpo To Decide Afresh With Certain Directions, However, Luxottica India Eyewear Pvt. Ltd. Vs. Acit Ground In Respect Of Tp Adjustment Made Towards International Transactions Of Import Of Finished Goods Remained Un-Adjudicated.

Section 143(3)Section 92C

order dt. 7.3.2005 for the AY 2002-03 and order dt. 20.3.2006 for the AY 2003-04, has agreed with the computation of arm's length price made by the assessee under the resale price method. Luxottica India Eyewear Pvt. Ltd. vs. ACIT (ii) In the case of L'Oreal ... Transactional Net Margin Method (TNMM) to the resale price met (RPM) as the most appropriate method (MAM) for the purposes determination of the arm’s length price (ALP). The Court sees no reason interfere since the adoption of the RPM by the Assessee was indeed found

DCIT, Circle 3 4, Mumbai vs. Tata Consultancy Services Limited, Mumbai

In the result, appeals of both, revenue and assessee are partly

ITA 2244/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 92CSection 92C(3)

fees 30,42,30,780 | Other method 4.1. Reference u/s. 92CA(1) was made to ld. Transfer Pricing Officer (TPO) for computing the Arm’s Length Price (ALP) in respect of international transactions. We now take up the above tabulated issues, seriatim: I. Provision of software, technical and consultancy Services

Tata Consultancy Services Limited, Mumbai vs. Deputy Commissioner of Incometax 3(4), Mumbai

In the result, appeals of both, revenue and assessee are partly

ITA 1517/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 92CSection 92C(3)

fees 30,42,30,780 | Other method 4.1. Reference u/s. 92CA(1) was made to ld. Transfer Pricing Officer (TPO) for computing the Arm’s Length Price (ALP) in respect of international transactions. We now take up the above tabulated issues, seriatim: I. Provision of software, technical and consultancy Services

M/S. Gulbrandsen Technologes (India) Pvt. Ltd, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

ITA 160/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand Vasant Mahadeokarआयकर अपील सं /Ita No. 160/Ahd/2022 िनधा"रण वष" /Assessment Year : 2017-18 M/S Gulbrandsen Additional/Joint/Deputy/ बनाम/ Technologies (India) Private Assistant Commissioner Of V/S. Limited Income Tax/Income-Tax 405, Synergy Square, Krishna Officer- Industrial Estate, Gowra, National Faceless Assessment Vadodara 390 016 Centre, Delhi "थायी लेखा सं./Pan: Aabcg 9006 E (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Mahesh Agarwal, Ar Revenue By : Shri Kalpesh Rupavatia, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 30/09/2025 घोषणा की तारीख /Date Of Pronouncement: 23/12/2025 आदेश/O R D E R

For Appellant: Shri Mahesh Agarwal, ARFor Respondent: Shri Kalpesh Rupavatia, Sr. DR
Section 143(3)Section 144CSection 144C(13)

thereby invalidating the entire assessment. Ground No. 3: The learned Transfer Pricing Officer (hereinafter referred to as "TPO") erred in computation of Arm's Length Price (hereinafter referred to as "ALP") with respect to Interest on External Commercial Borrowings (hereinafter referred to as "ECB") obtained from the associated enterprise ... assessment for AYs 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 & 2016-17 had accepted the same at Arm’s Length Price (ALP). It has been further pleaded that the said rate of interest @ 5.5%, throughout the period since 2005, has never been changed

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

lotus brand products. The assessee got manufacture the products from LHCC and KC and the sale price paid to them was at arm’s length price which fact has not been denied by the AO. The purchases from M/s LHCC were started in 2004 and from DCIT vs. Lotus Hearbals ... responsibility of the assessee who is trading the goods under the brand Lotus. Since the purchases price paid for these products was at arm’s length price which has not been doubted in any of the year since the assessee started these product manufactured from these two sister concerns

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

lotus brand products. The assessee got manufacture the products from LHCC and KC and the sale price paid to them was at arm’s length price which fact has not been denied by the AO. The purchases from M/s LHCC were started in 2004 and from DCIT vs. Lotus Hearbals ... responsibility of the assessee who is trading the goods under the brand Lotus. Since the purchases price paid for these products was at arm’s length price which has not been doubted in any of the year since the assessee started these product manufactured from these two sister concerns

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

lotus brand products. The assessee got manufacture the products from LHCC and KC and the sale price paid to them was at arm’s length price which fact has not been denied by the AO. The purchases from M/s LHCC were started in 2004 and from DCIT vs. Lotus Hearbals ... responsibility of the assessee who is trading the goods under the brand Lotus. Since the purchases price paid for these products was at arm’s length price which has not been doubted in any of the year since the assessee started these product manufactured from these two sister concerns

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

lotus brand products. The assessee got manufacture the products from LHCC and KC and the sale price paid to them was at arm’s length price which fact has not been denied by the AO. The purchases from M/s LHCC were started in 2004 and from DCIT vs. Lotus Hearbals ... responsibility of the assessee who is trading the goods under the brand Lotus. Since the purchases price paid for these products was at arm’s length price which has not been doubted in any of the year since the assessee started these product manufactured from these two sister concerns