DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, DUGGIRALA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 92C, the difference to the extent of 3% is permissible. We further find that the assessee by submitting all the details explained before the TPO that the assessee has charged for AE as well as non-AE similar prices for the supply of instant Page No. 15 ITA NO. 97, 98 & 152/Viz/2025 DCIT VS. CCL PRODUCTS INDIA LIMITED coffee

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 92C, the difference to the extent of 3% is permissible. We further find that the assessee by submitting all the details explained before the TPO that the assessee has charged for AE as well as non-AE similar prices for the supply of instant Page No. 15 ITA NO. 97, 98 & 152/Viz/2025 DCIT VS. CCL PRODUCTS INDIA LIMITED coffee

DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

section 92C, the difference to the extent of 3% is permissible. We further find that the assessee by submitting all the details explained before the TPO that the assessee has charged for AE as well as non-AE similar prices for the supply of instant Page No. 15 ITA NO. 97, 98 & 152/Viz/2025 DCIT VS. CCL PRODUCTS INDIA LIMITED coffee

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

disallowance of the royalty paid by the assessee-company for technical support services of Rs. 20,72,84,822/-, the Ld.AR submitted that the AO/TPO, while making the aforesaid addition, had erred in rejecting the benchmarking analysis furnished by the assessee and determined the ALP of the said International Transaction at Nil. Elaborating on his contention, the Ld.AR submitted that