TATA COMMUNICATIONS LIMITED,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX, MUMBAI
In the result, the question of law referred to the Special Bench is answered in favour of the assessee
ITA 3515/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19
Bench: Shri Saktijit Dey & Shri Arun Khodpiatata Communications Limited Pr. Cit, Videsh Sanchar Bhavan, Mumbai-1 Vs. M. G. Road, Fort, Mumbai-400 001 Pan/Gir No. Aaacv 2808 C (Appellant) : (Respondent) Appellant By : Shri J. D. Mistri Respondent By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: The Present Appeal, At The Instance Of The Assessee, Assails Order Dated 21.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short), By Learned Principal Commissioner Of Income Tax (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Though The Assessee Has Raised Multiple Grounds, Both On Jurisdictional Issues As Well As On Merits, However, There Is Consensus Between The Parties That The Appeal Can Be Decided On Merits, In Which Event, There Is No Need To Go Into Various Other Issues Raised In Appeal.
For Appellant: Shri J. D. MistriFor Respondent: Shri Ritesh Misra, CIT DR
Section 112Section 143(3)Section 263Section 50
54,850/-. Since in the year under dispute, the assessee had entered into international transactions with its Associated Enterprises (‘AE’ for short), the Assessing Officer (‘A.O.’ for short) made a reference to Transfer Pricing Officer (‘TPO’ for short) for determining the arm’s length price (ALP) of the international transaction. Insofar as, domestic transactions are concerned, A.O. called
