This compilation indexes twelve income-tax rulings — spanning ITAT benches at Delhi, Chennai, Pune, and Hyderabad, as well as the Karnataka High Court — in which Section 92C(2) of the Income Tax Act, 1961 was a cited provision. The cases range from 2018 to 2026 and arise primarily from disputes over Arm's Length Price (ALP) determination in international transactions with Associated Enterprises (AEs), comparable company selection, and Transfer Pricing Officer (TPO) adjustments. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured reference index for Section 92C(2) litigation across forums and years.

Research index only. This page is a structured case-law reference compiled for research purposes. It does not constitute legal or tax advice. Readers should verify all rulings against the full text of the judgment and check for any subsequent stays, reversals, or appellate proceedings before relying on any entry.

The statutory framework in one paragraph

Section 92C of the Income Tax Act, 1961 governs the computation of Arm's Length Price (ALP) in respect of international transactions between associated enterprises. Sub-section (2) of Section 92C — the provision central to all rulings in this index — provides that where more than one price is determined by the most appropriate method, the arm's length price shall be taken to be the arithmetical mean of such prices; and where the arithmetical mean so determined is within a range notified by the Central Government, the transaction price declared by the assessee shall be deemed to be the arm's length price. The Finance Act, 2014 substituted the original "five percent" standard deviation tolerance band with a range-based approach, and the Central Government has from time to time issued rules specifying the permissible range and the applicable percentile for the set of comparable prices. Section 92C(2) is typically engaged whenever a TPO or assessing officer proposes a transfer pricing adjustment to an international transaction, making it one of the most frequently litigated sub-sections in Indian transfer pricing jurisprudence.

The 12 rulings

1. Icl Management & Trading India Private vs DCIT, Circle -10(1), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 July 2026
Sections engaged: 144C(10), 144C(5), 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT (TP) A No.22/Del/2025) was filed by ICL Management and Trading India Pvt. Ltd. (PAN: AACCI5527P) for Assessment Year 2022-23 against the order of DCIT, Circle-10(1), Delhi. Per the source preview, two effective issues arose for adjudication: (i) a transfer pricing adjustment of Rs 4,68,84,744 made to the ALP of the international transaction of purchase of specialty fertilizers from Associated Enterprises, consequent to the exclusion of two comparable companies — Nikhil Adhesives Limited and Solvo-chem (India) Private Limited; and (ii) an adjustment of Rs 64,957 made towards notional interest on delayed receivables from the AEs.

2. Sanden Vikas India Private Limited,New vs ACIT, Tp Delhi 3(1)(2), New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 22 July 2026
Sections engaged: 270A, 92C, 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1754/Del/2021) was filed by Sanden Vikas India Pvt. Ltd. (PAN: AABCS3174M) for Assessment Year 2017-18. Per the source preview, the assessee was engaged in manufacturing of Car Air Conditioner Systems and Components such as compressors, HVAC units, cooling units, evaporators, condensers, hose & pipes, and Receiver Drier for sale primarily to unrelated parties in India; 50% shareholding was held by Sanden International Ltd., Singapore and Sanden Holdings Corporation, Japan, and the remaining 50% by the Indian shareholders (Vikas group). The appeal arose from grounds relating to international transactions carried out by the assessee, with the source preview not disclosing the full dispositive findings within the available extract.

3. Saipem India Projects Private vs ACIT Company Circle Vi(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 143(3), 144C, 195, 40(a), 9(1)(vi), 92C, 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT(TP)A No.8/CHNY/2018) was filed by Saipem India Projects Private Limited (PAN: AAACI7915F) for Assessment Year 2013-14 before the ITAT Chennai 'D' Bench. Per the source preview, the order lists a set of comparables with margins — including Cades Digitech Private Limited (5.96%), Neilsoft Limited (12.97%), I-Design Engineering Solutions Ltd (12.12%), Tata Consulting Engineers Ltd (12.86%), Shrishti Urban Infrastructure Development Ltd (16.03%), and MN Dastur and Company Pvt Ltd (-15.50%) — yielding a mean/average margin of 7.41%; the substantive findings on the transfer pricing adjustment within the available extract are not detailed beyond this comparable set.

4. M/S Hyundai Motor India Limited vs ACIT, ITO, National E-Assessment

Bench: Income Tax Appellate Tribunal - Chennai
Date: 9 February 2024
Sections engaged: 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT(TP)A No.53/Chny/2022) was filed by M/s. Hyundai Motor India Ltd. (PAN: AAACH-2364-M) for Assessment Year 2018-19. Per the source preview, the appeal arises out of a final assessment order passed pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru-3 under Section 144C(5), since the assessee carried out international transactions; the full substantive transfer pricing findings are not reproduced within the available preview extract.

5. Jas Forwarding Worldwide Pvt. Ltd., New vs DCIT, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 26 July 2021
Sections engaged: 92C, 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals — ITA No. 2484/Del/2014 (Assessment Year: 2009-10) and ITA No. 1687/Del/2016 (Assessment Year: 2011-12) — were filed by Jas Forwarding Worldwide Pvt. Ltd. (PAN: AABCJ5564A) against DCIT, Circle-4(1), New Delhi. Per the source preview, the order contains a table of comparables used for the transfer pricing analysis, listing entities such as Om Logistics Ltd (10.34), Sical Logistics Ltd (6.57), Arcadia Shipping Ltd (7.68), Good Earth Maritime Ltd (37.89), Sun Mar Shipping Ltd (23.02), PL Shipping and Logistics Private Limited (3.17), and Sindhu Cargo Services Ltd (8.13), with an arithmetic mean of 13.83; the dispositive findings on the ALP determination are not reproduced in full within the available extract.

6. Globe Ground India Pvt. Ltd., New Delhi vs DCIT, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 30 June 2021
Sections engaged: 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A No.5711/Del/2012) was filed by Globe Ground India Pvt. Ltd. (PAN: AAACG 8313K) for Assessment Year 2008-09. Per the source preview, the sole issue in dispute is the Transfer Pricing Adjustment of Rs 3,53,24,242/- proposed by the Transfer Pricing Officer (TPO) and sustained by the Disputes Resolution Panel (DRP); the assessee filed the appeal against the final order of assessment under Section 143(3)/144C of the Income Tax Act, 1961.

7. Synechron Technologies Pvt.Ltd,, Pune vs Assistant Commissioner Of Income-Tax

Bench: Income Tax Appellate Tribunal - Pune
Date: 22 January 2021
Sections engaged: 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1692/PUN/2018) was filed by Synechron Technologies Private Limited (PAN: AAICS2894R) for Assessment Year 2014-15, arising from the directions of the Dispute Resolution Panel (DRP), Panel-3, Mumbai passed under Section 144C(5). Per the source preview, the assessee's international transactions included provision of software development services (Rs 409,04,02,898, TNMM method), recovery of expenses (Rs 1,78,90,314, at actuals), and reimbursement of expenses (Rs 3,82,09,150, at actuals), totalling Rs 414,65,02,362.

8. Gss Infotech Limited , Hyderabad vs Income Tax Officer, Ward-2(2)

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 23 January 2020
Sections engaged: 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals — ITA No. 2255/Hyd/2017 and ITA No. 2367/Hyd/2018 — were filed by GSS Infotech Ltd., Hyderabad (PAN: AADCM 6759Q) for Assessment Years 2013-14 and 2014-15. Per the source preview, the assessee company is the parent company and GSS Infotech Inc. is its subsidiary in the USA; the assessee filed its return of income for AY 2013-14 on 26/09/2013 declaring a loss of Rs. 4,19,75,000/-, the return was selected for scrutiny under CASS, and determination of ALP of the international transaction was referred to the TPO, who vide order dated 31/10/2016 proposed a transfer pricing adjustment.

9. Commissioner Of Income Tax vs M/S.Symbol Technologies

Bench: Karnataka High Court
Date: 17 July 2018
Sections engaged: 260, 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This income tax appeal (I.T.A. No.173/2015) was filed by the Revenue before the Karnataka High Court under Section 260-A of the Income Tax Act, 1961, arising out of the order dated 19/12/2014 passed by the ITAT, 'A' Bench, Bangalore in IT(TP)A No.1352/Bang/2011 for Assessment Year 2007-08. Per the source preview, the Revenue prayed to decide the questions of law and/or set aside the appellate order of the ITAT; the substantive findings of the High Court are not reproduced within the available preview extract.

10. The Commissioner Of Income Tax vs M/S Cisco Systems (India) Pvt Ltd

Bench: Karnataka High Court
Date: 11 July 2018
Sections engaged: 92C(2), 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: This ITA (I.T.A. No.379/2013) was filed by the Revenue before the Karnataka High Court under Section 260-A of the Income Tax Act, 1961, arising out of the order dated 28/03/2013 passed by the ITAT, Bangalore in ITA No.1076/Bang/2011 for Assessment Year 2007-2008. Per the source preview, the Revenue prayed to formulate substantial questions of law, set aside the ITAT order, and confirm the orders passed by the Dispute Resolution Panel, Transfer Pricing Officer, and the Assessment Order passed by the Deputy Commissioner of Income Tax, Circle-11(2), Bangalore; the High Court's substantive findings are not reproduced within the available preview extract.

11. The Commissioner Of Income Tax vs M/S Kodiak Networks (India) Pvt Ltd

Bench: Karnataka High Court
Date: 10 July 2018
Sections engaged: 92C(2), 260
Outcome: Outcome not specified in source
Procedural / substantive ground: This ITA (I.T.A. No.183/2012) was filed by the Revenue before the Karnataka High Court under Section 260-A of the Income Tax Act, 1961, arising from the order of the ITAT, Bangalore in ITA No.1413/Bang/2010 dated 27-01-2012. Per the source preview, the Revenue prayed to formulate substantial questions of law, set aside the ITAT order, and confirm the order of the Appellate Commissioner confirming the order passed by the Assistant Commissioner of Income Tax, Circle-11(5), Bangalore; the substantive transfer pricing findings of the High Court are not reproduced within the available preview extract.

12. Commissioner Of Income vs M/S Tatra Vectra Motors Ltd

Bench: Karnataka High Court
Date: 10 July 2018
Sections engaged: 92C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This ITA (I.T.A. No.191/2012) was filed by the Revenue before the Karnataka High Court under Section 260-A of the Income Tax Act, 1961, arising from the order of the ITAT, 'A' Bench, Bangalore in ITA No.1284/Bang/2010 dated 31/01/2012 for Assessment Year 2006-07. Per the source preview, the appellants-Revenue raised purportedly certain substantial questions of law from the ITAT order and prayed to decide those questions; M/s. Tatra Vectra Motors Ltd. is now known as Kamaz Vectra Motors Limited per the source preview.

Patterns across these 12 rulings

DRP as the near-universal intermediate step. Across multiple ITAT cases in this index — including those involving ICL Management, Hyundai Motor India, Synechron Technologies, and GSS Infotech — the final assessment order appealed against was passed pursuant to directions issued by a Dispute Resolution Panel under the applicable provisions of Section 144C. The DRP route appears to be the standard pre-ITAT procedural pathway in transfer pricing matters for the cases captured here.
Comparable company selection as the dominant live dispute. Several ITAT cases (ICL Management, Saipem India Projects, Jas Forwarding Worldwide) expressly surface the exclusion or inclusion of specific comparable companies as the core factual controversy, with the orders recording the names and margins of the comparables considered. This signals that the practical battleground under Section 92C(2) frequently concerns which companies qualify as comparables rather than the arithmetic or tolerance-band computation itself.
Karnataka High Court cluster — Revenue filing Section 260-A appeals. Four of the twelve rulings (Symbol Technologies, Cisco Systems, Kodiak Networks, Tatra Vectra Motors) are Revenue-initiated appeals filed before the Karnataka High Court under Section 260-A, all from the same period (July 2018) and all seeking to set aside or question ITAT orders on transfer pricing. This cluster suggests a period of active Revenue litigation at the High Court level in Bangalore challenging ITAT transfer pricing outcomes.
Multi-year consolidated appeals. At least two cases in this index — Jas Forwarding Worldwide (AY 2009-10 and AY 2011-12) and GSS Infotech (AY 2013-14 and AY 2014-15) — involve multiple assessment years being adjudicated together in a single proceeding, a common efficiency mechanism in prolonged transfer pricing disputes where the same entity and transaction type recur across years.
Diverse industry coverage under the same sub-section. The twelve cases span fertilizer trading (ICL Management), automobile air conditioning components (Sanden Vikas), engineering and project services (Saipem), automotive manufacturing (Hyundai Motor India), freight forwarding and logistics (Jas Forwarding, Globe Ground), IT and software services (Synechron Technologies, GSS Infotech, Kodiak Networks, Symbol Technologies, Cisco Systems), and automotive equipment (Tatra Vectra Motors). Section 92C(2) thus operates as a cross-sectoral provision, and the comparable-selection methodology varies significantly across these industry contexts.

How to use this compilation

This index is a starting point for locating Section 92C(2) rulings across ITAT benches and the Karnataka High Court over the period 2018 to 2026. For each entry, researchers should retrieve the full text of the judgment from the official court portal, indiankanoon.org, or the ITAT e-filing portal before drawing any conclusion about the holding, the specific grounds decided, or the relief granted. The "Outcome not specified in source" flag on every entry in this compilation means the structured data does not carry a machine-readable dispositive result; the full order must be read to determine whether the appeal was allowed, dismissed, partly allowed, or remanded.

Researchers should also check whether any of these orders have been subjected to further appellate proceedings. An ITAT order may have been challenged before the High Court; a High Court order at the admission or hearing stage may have proceeded to a final judgment; and any final judgment may itself have been taken to the Supreme Court. The dates in this index reflect the date of the specific order captured in the source data, not necessarily the date of the final disposal of the litigation chain.

Finally, transfer pricing positions are also shaped by CBDT circulars, safe harbour rules, and advance pricing agreements (APAs) that operate alongside judicial precedent. Any research workflow on Section 92C(2) should cross-reference current CBDT instructions on the permissible range and percentile thresholds applicable under sub-section (2), which have been revised over time through the Income Tax Rules, to understand the regulatory backdrop against which these rulings were decided.

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 92C(2) Transfer Pricing ALP: 12 ITAT & HC Rulings Compiled