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M/S. Farida Classic Shoes Pvt. ... vs Acit, Cc-3(2), Chennai on 26 May, 2026 cites

Acit, Chennai vs Naresh Prasad Agarwal, Chennai on 27 June, 2018

consequently an erroneous determination of the arm's length margin. In this regard the ld.AR placed reliance on the decision in Microsoft India (P.) Ltd. v. DCIT, wherein the Tribunal has held that there must be parity in the treatment of income and corresponding expenses while computing operating margins, and selective exclusion results in an artificial skewing of profitability. In view of the aforesaid arguments, the ld.AR submitted that the guest house expenditure be excluded from operating expenses, in line with the treatment accorded to the corresponding income, so as to ensure a consistent and accurate computation of the Profit Level Indicator (PLI) and to avoid any distortion in the determination of the Appellant's arm's length margin.
Income Tax Appellate Tribunal - Chennai Cites 45 - Cited by 19 - Full Document

M/S Liberty India vs Commr.Of Income Tax,Karnal on 31 August, 2009

derives export revenue and the comparables have mixed operational profiles. Accordingly, we hold that the reliance placed by the Revenue authorities on Liberty India v. CIT is misplaced in the transfer pricing context and export incentives such as DEPB, Duty Drawback, MEIS and similar incentives are liable to be treated as operating income for the purpose of computation of operating margins under TNMM. Therefore, the AO/TPO is directed to include export incentives as part of operating income while computing the PLI of the assessee. Hence, the ground raised by all the assessees for the respective assessment years referred in para 12.1 (supra) are allowed.
Supreme Court of India Cites 21 - Cited by 862 - S H Kapadia - Full Document

Cit vs Alfa Laval (India) Ltd. on 1 November, 2007

9.19 It is a settled principle of accounting and taxation that closing stock is ordinarily to be valued at cost or net realizable value, whichever is lower. Reduction in the value of obsolete, damaged or non-moving stock based on realizable market value is a recognized and accepted accounting principle. The Hon'ble Supreme Court in CIT vs Alfa Laval (India) Pvt. Ltd. has recognized the permissibility of valuation of obsolete inventory at realizable value where such IT(TP) A. No.1-5/Chny/2026 & 42-53/Chny/2025 M/s Farida, Delta, Aston & India Shoes Pvt Ltd Vs ACIT CC-3(2) :: 38 ::
Supreme Court of India Cites 0 - Cited by 19 - Full Document

Canon India Private Limited, Gurugram vs Dcit (Tp)-1(2)(1), New Delhi on 25 February, 2022

is settled law that the TPO/AO is bound by the directions of the DRP and cannot deviate from the same. Such non-compliance vitiates the assessment and renders the order unsustainable in law. 14.6 Further, the ld.AR stated that the issue is squarely covered by the coordinate bench decision of the Tribunal in ZF Rane Automotive India (P.) Ltd. v. DCIT- IT(TP)A No.53/CHNY/2024 dated 04.08.2025, wherein the Tribunal, while dealing with an identical issue (Page 15 para 9 to Page 17 para 9.4), has held that miscellaneous expenses are part of normal business operations and must be treated as operating expenses. The Tribunal has categorically observed that:
Income Tax Appellate Tribunal - Delhi Cites 2 - Cited by 2 - G S Pannu - Full Document

Cognizant Technology Solutions India ... vs Ito, Chennai on 20 November, 2018

Further, the Tribunal in Netradyne Technology India Pvt. Ltd. v. ITO observed that comparability filters must be applied uniformly and scientifically and cannot be modified selectively to suit the outcome desired by the Revenue authorities. The Tribunal held that arbitrary exclusion of comparables distorts the determination of arm's length price and defeats the object of transfer pricing analysis. 13.13 We also find force in the alternate contention of the assessee regarding consistency. It is an admitted position that for AY 2019-
Income Tax Appellate Tribunal - Chennai Cites 6 - Cited by 0 - Full Document

Orange Business Services India ... vs Dcit, Circle-3, Gurgaon on 15 February, 2018

dissimilarity. At this juncture, it is relevant to refer to the decision of the coordinate bench in Orange Scape Technologies Pvt. Ltd. v. DCIT wherein the coordinate bench of the Tribunal reiterated that only persistent loss-making companies are liable to be excluded and not companies suffering normal business losses. The Tribunal emphasized that the persistent loss filter must be applied consistently and objectively.
Income Tax Appellate Tribunal - Delhi Cites 12 - Cited by 34 - Full Document
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