APOLLO TYRES LTD,COCHIN vs. THE DEPUTY COMMISSIONER OF INCOME TAX, COCHIN

In the result, this ground of appeal stands allowed

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2021-22 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

Transfer Pricing documentation is maintained as per the provisions of the Indian Transfer Pricing Law, and in the absence of any defect

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

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

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

transfer price of Rs. 234.09 per kg. for the original transfers is taken as the base. The transfer price in Andhra

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

price based on TNMM. However, the TPO was not satisfied with the transfer pricing study of the assessee with respect

APOLLO TYRES LTD.,COCHIN vs. DCIT CORPORATE CIR 1(1), KOCHI

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

Transfer Pricing documentation is maintained as per the provisions of the Indian Transfer Pricing Law, and in the absence of any defect

M/S.JOY ALUKKAS INDIA P. LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

transfer pricing provisions under section 92B. The DRP failed to appreciate that the Transfer Pricing Officer had on its own benchmarked

M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

transfer pricing provisions under section 92B. The DRP failed to appreciate that the Transfer Pricing Officer had on its own benchmarked

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

Transfer Pricing Officer ("TPO") grossly erred in making transfer pricing addition of Rs. 3,48,96,832/- (as detailed in bellows

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed\nfor statistical purpose and the stay application is dismissed as\ninfructuous

transfer pricing adjustments made by the Assessing Officer (AO) and Transfer Pricing Officer (TPO) regarding IT services and interest on delayed

THE DCIT, KOCHI vs. M/S.NETWORK SYSTEMS & TECHNOLOGIES P. LTD, ALUVA

In the result, the appeals filed by the Revenue stand partly allowed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

Transfer Pricing Officer (TPO) u/s. 92CA(3) of the Income Tax Act, 1961 (the Act) for the purpose of benchmarking

THE DCIT, KOCHI vs. M/S.NETWORK SYSTEMS & TECHNOLOGIES P. LTD, ALUVA

In the result, the appeals filed by the Revenue stand partly allowed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

Transfer Pricing Officer (TPO) u/s. 92CA(3) of the Income Tax Act, 1961 (the Act) for the purpose of benchmarking

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

Transfer Pricing Officer (TPO) u/s 92CA (l) of the Actfor determining the arm's length price in respect of the International

OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,HARYANA vs. ITO, WARD 1 & TPS, KOLLAM

In the result, appeal of the assessee is partly allowed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

Transfer Pricing Officer (in short “TPO”) for the purpose of benchmarking the international transactions. Thereafter, the TPO vide order dated

OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,HARYANA vs. ITO, WARD 1 & TPS, KOLLAM

In the result, appeal of the assessee is partly allowed

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

Transfer Pricing Officer (in short “TPO”) for the purpose of benchmarking the international transactions. Thereafter, the TPO vide order dated

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

Bench: Shri George George K. & Ms. Padmavathy S.

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

FEDBANK FINANCIAL SERVICES LIMITED,ERNAKULAM vs. THE DCIT CIRCLE 1(1), KOCHI, KOCHI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Ms. Padmavathy S.Assessment Year : 2017-18

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared

SILLS KARINGATTIL JOSE,NEDUMKANDOM vs. ITO WARD 2, THODUPUZHA

Appeal is partly allowed for statistical purpose

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsils Karingattil Jose Income Tax Officer Np 3/406, Karingattil Ward - 2, House, Munnar Road Thodupuzha Vs. Nedumkandom P.O. [Pan: Afopj8789C] (Appellant) (Respondent)

transfer of shares of a company to a firm or a company, instead of an individual or an HUF, without consideration or at a price