This compilation indexes twelve income-tax rulings — spanning ITAT benches at Bangalore, Cochin, Vizag, Hyderabad, and Pune, and High Courts at Delhi and Karnataka — that engage Section 92B of the Income Tax Act, 1961. The rulings span May 2024 to June 2026 and cover a range of transfer pricing contexts including software-development service transactions, AMP expenditure characterisation, arm's length price determination, and specified domestic transactions. The compilation is intended as a structured research reference for in-house tax teams, Big-4 associates, and law-firm researchers who need to locate and verify primary source material on Section 92B disputes.

Research index only. This page organises publicly available case data for research purposes. Nothing on this page constitutes legal or tax advice. Readers must verify all citations against the full judgment text and check for subsequent stays, reversals, or appeals before relying on any ruling.

The statutory framework in one paragraph

Section 92B of the Income Tax Act, 1961 defines the term "international transaction" for the purposes of Chapter X (Transfer Pricing). It provides that an "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale, or lease of tangible or intangible property; provision of services; lending or borrowing of money; or any other transaction having a bearing on the profits, income, losses, or assets of such enterprises. The Explanation inserted by the Finance Act, 2012 (with retrospective effect from 1 April 2002) expanded the definition to include, among other things, a transaction of business restructuring or reorganisation between associated enterprises, and also clarified that a transaction entered into by an enterprise with a person other than an associated enterprise shall be deemed to be an international transaction if there exists a prior agreement in relation to the relevant transaction between that other person and the associated enterprise, or the terms of the relevant transaction are determined in substance between that other person and the associated enterprise.

The 12 rulings

1. Ntt Data Fa Insurance Systems (India) vs The Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 29 June 2026
Sections engaged: 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee — a private limited company and subsidiary of NTT Data FA Insurance Systems Pte Ltd., Singapore — challenging the final assessment order dated 27/06/2024 in respect of Assessment Year 2020-21 (ITA(TP)A No. 1557/Bang/2024). The assessee is stated to be in the business of providing software development services to its parent company, and the appeal was heard on 01-04-2026 and pronounced on 29-06-2026 per the source preview.

2. M/S.Ibs Software Services P vs The DCIT, Trivandrum

Bench: Income Tax Appellate Tribunal - Cochin
Date: 13 November 2025
Sections engaged: 92B, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The present appeal (IT(TP)A ITA No. 601/COCH/2017) was preferred by the assessee pertaining to Assessment Year 2013-2014, challenging the Final Assessment Order dated 18/09/2017 passed by the Assessing Officer. The hearing concluded on 19.08.2025 and the order was pronounced on 13.11.2025 per the source preview.

3. M/S.Joy Alukkas India P. Ltd,Cochin vs The ACIT, Cochin

Bench: Income Tax Appellate Tribunal - Cochin
Date: 8 September 2025
Sections engaged: 36(1)(iii), 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: These are appeals filed by the assessee-company directed against different final assessment orders dated 29/01/2016, 27/12/2016, and 30/10/2017 for Assessment Years 2011-12, 2012-13, and 2013-14 respectively (IT(TP)A No. 119/Coch/2016 and IT(TP)A Nos. 38 & 643/Coch/2017). Since identical issues and facts were involved in all three appeals, they were heard together and disposed of by a common order per the source preview.

4. Deputy Commissioner Of Income Tax vs Ccl Products (India) Limited

Bench: Income Tax Appellate Tribunal - Vizag
Date: 10 June 2025
Sections engaged: 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (I.T.A. Nos. 97, 98, and 152/Viz/2025) were filed by the Department and pertain to Assessment Years 2011-12, 2012-13, and 2016-17 in the case of CCL Products (India) Limited (PAN: AAACC9552G), Guntur, Andhra Pradesh. The hearing concluded on 02/06/2025 and the order was pronounced on 10/06/2025 per the source preview.

5. PCIT-1, New Delhi vs Beam Global Spirits & Wine (India) Pvt

Bench: Delhi High Court
Date: 7 March 2025
Sections engaged: 92B, 92F
Outcome: Outcome not specified in source
Procedural / substantive ground: These two appeals (ITA 155/2022 and ITA 156/2022) pertain to Assessment Years 2009-10 and 2012-13 and raise the question of whether Advertisement, Marketing and Promotion (AMP) expenditure incurred by the respondent-assessee would constitute an "international transaction" as contemplated under the relevant transfer pricing provisions. The source preview records a table of international transactions including purchase of compound alcoholic preparation, distribution of imported liquor, provision of marketing support services, re-imbursement of expenses, and recovery of expenses, with the AMP expenditure noted as Rs. 1,119,028,161 representing 35.69% of gross sales.

6. Commissioner Of Income Tax vs Benetton India Pvt. Ltd

Bench: Delhi High Court
Date: 6 February 2025
Sections engaged: 92B, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA 472/2018, ITA 1318/2018, and ITA 1319/2018) were filed by the Commissioner of Income Tax against Benetton India Pvt. Ltd. The source preview references the roles of foreign personnel deputed to India — covering international sourcing, production supervision, and buying and visual media activities — and also references a royalty rate table relating to a foreign collaborator, indicating that the dispute engaged questions of characterisation and arm's length pricing of related-party transactions.

7. New Delhi Television Limited vs Assistant Commissioner Of Income Tax

Bench: Delhi High Court
Date: 29 January 2025
Sections engaged: 92B, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee impugned the validity of the Income Tax Appellate Tribunal's judgment dated 16 June 2020 in ITA 204/2020. The appeal pertains to Assessment Year 2008-09 and relates to inquiries initiated by the Investigating Wing of the Income Tax Department in connection with certain Step-up Coupon Bonds of USD 100 Million issued by the appellant's U.K. subsidiary M/s NDTV Networks PLC outside India to various investors. The Delhi High Court had admitted the appeal on questions of law by an order dated 09 February 2024 per the source preview.

8. Sanghi Industries Limited,Hyderabad vs DCIT, Circle -3 (1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 23 January 2025
Sections engaged: 92E, 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA (TP) No. 104/Hyd/2022) was filed by the assessee feeling aggrieved by the assessment order passed by the Assessing Officer / Dispute Resolution Panel for Assessment Year 2017-18. The source preview discloses a transfer pricing study table referencing transactions including transfer of power by an eligible unit to a non-eligible unit (Rs. 114,14,28,568), transfer of fly ash (Rs. 60,90,830), and allocation of expenses (Rs. 39,62,81,129), with a combined total noted in the order.

9. Fab India Overseas Private Limited vs Assistant Commissioner Of Income Tax

Bench: Delhi High Court
Date: 28 November 2024
Sections engaged: 32, 92B, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed W.P.(C) 3965/2021 impugning an order dated 28.01.2021 passed by the Transfer Pricing Officer relating to Assessment Year 2011-12. The petitioner also prayed for directions to the Assessing Officer to compute its claim of depreciation for AY 2011-12 in respect of the written down value of the trademark FABINDIA as on 01.04.2010. The purchase of the trademark was considered as an international transaction and the TPO rejected the transfer pricing documentation and analysis submitted by the petitioner, passing an order determining the arm's length price of the transaction per the source preview.

10. Pr. Commissioner Of Income Tax-2 vs M/S Tt Steel Service India Pvt Ltd

Bench: Karnataka High Court
Date: 14 October 2024
Sections engaged: 92B, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 665 of 2023) was filed under Section 260-A of the Income Tax Act, 1961, praying to set aside the appellate order dated 06/04/2023 passed by the Income Tax Appellate Tribunal, 'B' Bench, Bangalore in IT[TP]A No. 375/BANG/2021, which related to Assessment Year 2016-17. The challenge in the High Court was directed against the order passed by the Income Tax Appellate Tribunal per the source preview.

11. The Pr. Commissioner Of Income Tax vs Marlabs Innovations Pvt Ltd

Bench: Karnataka High Court
Date: 26 September 2024
Sections engaged: 92B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 523 of 2023) was filed under Section 260-A of the Income Tax Act, 1961 praying to allow the appeal, set aside the orders passed by the Income Tax Appellate Tribunal, Bengaluru in IT(TP)A No. 963/BANG/2022 dated 27.02.2023 for Assessment Year 2018-2019, and confirm the order of the DRP confirming the order passed by the Deputy Commissioner of Income Tax, Central Circle-4(1)(1), Bengaluru. The respondent assessee is Marlabs Innovations Pvt. Ltd. (PAN: AAECM6806F) per the source preview.

12. Uttam Energy Limited, Pune vs ACIT Circle-12, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 30 May 2024
Sections engaged: 92B, 40A(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2033/PUN/2019) was filed by the assessee against the final assessment order of the ACIT, Circle-12, Pune for Assessment Year 2015-16. The assessee (PAN: AABCU4100H) filed its return of income on 30/09/2015 and revised it on 26/03/2016. The case was selected for scrutiny, with one reason for selection being "Large Specified Domestic Transactions," following which the Assessing Officer referred the case to the Transfer Pricing Officer per the source preview.

Patterns across these 12 rulings

Software and technology service companies are heavily represented. Rulings 1 (NTT Data FA Insurance Systems), 2 (IBS Software Services), and 11 (Marlabs Innovations) all involve IT or software-sector entities providing services to related parties, reflecting the concentration of transfer pricing disputes in this sector.
Multi-year consolidated proceedings are common. In at least three rulings (cases 3, 4, and 6), multiple assessment years were clubbed and disposed of by a single common order, indicating that transfer pricing disputes under Section 92B frequently span several assessment years with overlapping issues.
Revenue authorities appeal ITAT orders to High Courts. Cases 5, 6, 7, 9, 10, and 11 are all proceedings before the Delhi High Court or Karnataka High Court, with either the Revenue or the assessee challenging ITAT findings, illustrating that Section 92B disputes routinely escalate beyond the tribunal tier.
AMP expenditure characterisation as an international transaction is a recurring issue. Case 5 (Beam Global Spirits & Wine) expressly raises the question of whether Advertisement, Marketing and Promotion expenditure constitutes an "international transaction," a contested question that has generated significant litigation under Section 92B.
Specified domestic transactions generate Section 92B-adjacent disputes. Case 12 (Uttam Energy) was selected for scrutiny on account of "Large Specified Domestic Transactions" and referred to the Transfer Pricing Officer, demonstrating that the transfer pricing machinery — including the definitional framework under Section 92B — is also engaged for domestic related-party transactions in certain contexts.

How to use this compilation

This compilation is organised as a research index and is intended as a starting point for locating primary source material. Each entry above identifies the forum, the date of the order, the ITA or writ petition number (where available in the source preview), and the sections engaged. Researchers should use these identifiers to retrieve the full text of each judgment from indiankanoon.org, the respective High Court's official portal, or the ITAT's ITAT.gov.in database before drawing any conclusions about the law or facts in a particular case.

Because all outcome fields in this compilation read "Outcome not specified in source," readers must consult the full judgment to determine the operative holding, the direction of the order (whether the appeal was allowed, dismissed, or partly allowed), and the precise reasoning. Summaries in any database — including this one — are not substitutes for the full text. Transfer pricing rulings in particular often turn on highly fact-specific comparability analyses, choice of method, and application of the arm's length range, none of which can be adequately captured in a short preview.

Researchers should also verify whether any of these orders have been subsequently stayed, reversed, or appealed further. High Court rulings under Section 260-A may be challenged before the Supreme Court, and ITAT orders may be challenged before the respective High Court. Additionally, CBDT circulars, safe harbour rules notified under Section 92CB, and Advance Pricing Agreements under Section 92CC may affect the continued relevance of earlier rulings to current fact patterns. Always cross-check the ruling's AY against any subsequent legislative amendments to the relevant provisions.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 92B Transfer Pricing: 12 ITAT and High Court Rulings (2024–2026)