BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

1,248 results for “transfer pricing”+ TP Methodclear

Sorted by relevance

Delhi1,462Mumbai1,248Bangalore1,166Pune262Kolkata252Chennai221Hyderabad195Ahmedabad156Karnataka63Indore35Visakhapatnam32Jaipur27Chandigarh21Cochin12Surat11Amritsar9Guwahati6Cuttack5Dehradun5Telangana5Rajkot4SC3Nagpur2Panaji2Ranchi1Raipur1Kerala1

Key Topics

Transfer Pricing78Section 143(3)67Section 92C61Addition to Income53Disallowance39Comparables/TP37Section 14A33Section 144C(5)25Section 115J

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. DCIT 9(3)(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

Transfer Pricing Officer, it can be restored back to him for determining arm's length price denovo by applying a correct method. In support of his contention, the learned Departmental Representative relied upon the following decisions:– i) M/s. Gemplus India Pvt. Ltd. v/s ACIT, ITA no.352/Bang./ 2009, dated 21.10.2010; ii) Cranes Software International Ltd. v/s DCIT, [2014] 52 taxmann.com

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

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

Showing 1–20 of 1,248 · Page 1 of 63

...
22
Deduction19
Penalty17
Section 144C(13)16
ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

Section 143(3)Section 144C(5)

transfer pricing adjustment in relation to export of finished goods. The facts with regard to the impugned dispute are that the assessee has exported finished goods to its AE. The assessee has benchmarked its transactions with AE in respect of sale of finished goods by applying TNMM as most appropriate method. The AO has rejected TP

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

method and reported margin of 21.52%. In the transfer pricing study undertaken through external consultant 16 companies were selected as comparable with average arithmetic mean of 21.85%. The Transfer Pricing Officer after perusing the transfer pricing study of the assessee noticed that the assessee has done financial analysis of the comparable companies on the basis of multiple year data instead

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

method. 027. Merely because invoices are prepared in a particular manner, they do not prove that goods sold in those products are inextricably linked with each other. 028. In view of this, we confirm the action of the lower authorities in making a transfer pricing adjustment with respect to sale of pharmaceutical products in Nigeria to associated enterprises amounting

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

Method (TNMM) with average margin of 11.06% as against the margin shown by the assessee at 15.26%. Hence, the price charged to the AE was claimed to be at arm's length. The Transfer Pricing Officer after examining the fresh list of comparables submitted by the assessee accepted some of the comparables while rejecting many. Having done so, the Transfer

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

method. After considering the submissions of the assessee along with details filed, the Transfer Pricing Officer was of the view that services rendered both under ITES and consultancy services segment are similar in nature. However, he proceeded to benchmark them separately. Insofar as ITES segment is concerned, the Transfer Pricing Officer selected seven companies as comparables with arithmetic mean

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 1916/MUM/2024[2012]Status: DisposedITAT Mumbai22 Oct 2024

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

For Appellant: Mr. Rajesh SanghaviFor Respondent: 20/08/2024
Section 271GSection 92Section 92CSection 92D

transfer pricing scrutiny, we would like to considers TNMM to be the most appropriate method for determination considers TNMM to be the most appropriate method for determination considers TNMM to be the most appropriate method for determination of ALP for the international transaction in lieu of CUP method of ALP for the international transaction in lieu of CUP method

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

method to benchmark the transaction. Pointing out various defects and deficiency, he rejected the transfer pricing analysis of the assessee and proceeded to determine the arm's length price of the transaction independently. Ultimately, the Transfer Pricing Officer selected six companies as comparable on the basis of current year data with arithmetic mean of 35.71%. Applying the arithmetic mean

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

TP assessment using lexis database) Average 6.45% 40 Viacom 18 Media Pvt. Ltd. 93. Considering average rate of royalty of 6.45% versus royalty paid by assessee @ 7%, the Transfer Pricing Officer made adjustment of ` 52,95,875. 94. The DRP upheld the action of the Transfer Pricing Officer. 95. Before us, the learned A.R. for the assessee submitted that

JOHNSON AND JOHNSON PRIVATE LIMITED,MUMBAI vs. ADDITIONAL COMMISSIONER OF INCOME TAX-LTU-1, MUMBAI

In the result, appeal is partly allowed

ITA 6142/MUM/2017[2008-09]Status: DisposedITAT Mumbai19 Sept 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwaljohnson & Johnson Pvt. Ltd. 501, Arena Space, Off Jvlr Opp. Majas Bus Depot ……………. Appellant Jogeshwari (East), Mumbai 400 060 Pan – Aaacj0866E V/S Addl. Commissioner Of Income Tax ……………. Respondent Ltu–1, Mumbai Assesseeby : Shri Rajan R. Vora A/W Shri Pranay Gandhi & Shri Harshvardhan Aggarwal Revenue By : Shri Jayant Kumar

For Appellant: Shri Rajan R. Vora a/wFor Respondent: Shri Jayant Kumar
Section 115JSection 143(3)Section 144C(13)Section 153Section 92C

methods of determining the ALP, makes it clear that the transfer pricing adjustment is made by substituting the ALP for the price of the transaction. To begin with there has to be an international transaction with a certain disclosed price. The transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 64. The transfer

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

method. However, for the purposes of comparing of Profit Level Indicator (PLI), assessee has chosen itself i.e. an Indian entity as tested party. However, the comparables were chosen pertaining to Asia Pacific Region. Therefore, the learned Transfer Pricing Officer rejected the transfer pricing study report of the assessee as no relevant data were available. The assessee was asked to provide