This compilation indexes twelve rulings from the Income Tax Appellate Tribunal (ITAT) benches across Delhi, Chennai, Hyderabad, Mumbai, and Bangalore, as well as the Delhi High Court and the Bombay High Court, all engaging Section 92C(3) of the Income Tax Act, 1961. The rulings span the period October 2021 to July 2026 and arise from disputes concerning the determination of arm's length price in international transactions, comparable selection, and Transfer Pricing Officer (TPO) adjustments. This index is intended for use by in-house tax teams, Big-4 transfer pricing practitioners, and law firm researchers who need a structured starting point for locating primary sources on Section 92C(3) litigation.

Research index only. This page is a structured case-law reference compiled from publicly available Indian tax tribunal and court orders. Nothing on this page constitutes legal or tax advice. Readers must independently verify each ruling, check for subsequent stays, appeals, or reversals, and obtain professional advice before acting on any information contained herein.

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 (3) of Section 92C empowers the Assessing Officer (AO) — generally acting on the basis of a report from the Transfer Pricing Officer under Section 92CA — to determine the ALP of a transaction where the ALP declared by the assessee is found to be not in accordance with the provisions of Section 92C. Where the AO is satisfied that the ALP determined by the assessee is not at arm's length, or where the assessee has failed to furnish the requisite information or documentation, the AO may compute the ALP in accordance with the prescribed rules and make an adjustment to the income of the assessee to the extent of the difference between the ALP so determined and the price actually charged or paid by the assessee. The scope of this sub-section is frequently contested in litigation, with disputes arising over comparable selection, choice of transfer pricing method, application of filters, and procedural compliance obligations.

The 12 rulings

1. ACIT Circle 25 (1), Delhi vs Viney Corporation Ltd. , Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 8 July 2026
Sections engaged: 92C, 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No.16/Del/2022 for assessment year 2016-17 was filed by the Revenue against the appellate order dated 10.08.2020 passed by the Commissioner of Income-tax (Appeals)-44, New Delhi under Section 250 of the Income Tax Act, 1961 (Appeal No. 194/2019-20/CIT(A)-44). That appellate order had itself arisen from an assessment order dated 31.12.2018 passed by the Assessing Officer (Order No. ITBA/AST/S/143(3)/2018-19/1014678824(1)). The source preview indicates the Revenue raised revised grounds of appeal before the Delhi Tribunal; the substantive outcome is not specified in the available source data.

2. Ivy Mobility Solutions Pvt vs DCIT, Corporate Circle-1(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 92B, 92C(3), 92E
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal by the assessee (IT(TP)A No.34/CHNY/2026, Assessment Year 2022-23, PAN: AABCE0269M) was filed against the final order of assessment passed by the National Faceless Assessment Unit under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961. The hearing concluded on 01-07-2026, with the order pronounced on 07-07-2026; the substantive outcome is not specified in the available source data.

3. M/S. Elgi Rubber Co, Ltd.,Coimbatore vs DCIT, Corp. Circle-1,, Coimbatore

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 92C, 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT(TP)A No. 07/Chny/2026, Assessment Year 2022-23, PAN: AABCE9596M) was heard on 17.06.2026 and pronounced on 07.07.2026. The source preview records transactions with associated enterprises including Elgi Rubber Company LLC (USA), Elgi Rubber Company Holdings BV (Netherlands), and Elgi Rubber Resources BV (Netherlands), with total amounts charged to these AEs aggregating Rs. 2,13,97,035; the substantive outcome on the transfer pricing issues is not specified in the available source data.

4. Sresta Natural Bioproducts Private vs DCIT., Circle-3(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 19 December 2025
Sections engaged: 92C, 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.711/Hyd/2024, Assessment Year 2020-2021, PAN: AAHCS9571J) was heard on 11.12.2025 and pronounced on 19.12.2025. The grounds of appeal, as reflected in the source preview, challenge the AO's rejection of the transfer pricing documentation, benchmarking analysis, and economic analysis submitted by the assessee, with the assessee contending that such rejection was based on inappropriate and unreasonable grounds. The substantive outcome is not specified in the available source data.

5. Indeed India Operations Private vs ACIT., Circle2(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 10 December 2025
Sections engaged: 92C(3), 144C(13), 153
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos.943 & 1359/Hyd/2024, Assessment Years 2020-2021 & 2021-2022, PAN: AADCI5931J) were heard on 03.12.2025 and pronounced on 10.12.2025. Per the source preview, the TPO and the AO, acting under directions issued by the Dispute Resolution Panel, were alleged to have erred in making a transfer pricing adjustment of INR 1,68,62,731 towards interest on outstanding receivables for Assessment Year 2020-2021. The substantive outcome is not specified in the available source data.

6. American Express Banking Corporation vs Assistant Director Of Income Tax

Bench: Delhi High Court
Date: 5 May 2025
Sections engaged: 92C, 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 5/2025) was filed by American Express Banking Corporation (India Branch) before the Delhi High Court. The source preview records the nature of the international transactions at issue, including provision of IT-enabled services (ALP determined by assessee: INR 19,95,90,000; ALP determined by TPO: INR 21,60,72,808; adjustment: INR 1,64,82,808) and intra-group services (ALP by assessee: INR 22,65,40,886; ALP by TPO: NIL; adjustment: INR 22,65,40,886), with a total adjustment of INR 24,30,24,147. The preview also records the TPO's remarks on various comparability filters applied during the benchmarking exercise; the substantive outcome is not specified in the available source data.

7. Pr. Commissioner Of Income Tax-4 vs Phoenix Comtrade Pvt. Ltd

Bench: Bombay High Court
Date: 17 April 2024
Sections engaged: 92C(1), 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed Income Tax Appeal (IT) No. 1188 of 2018 (along with IT No. 1204 of 2018) before the Bombay High Court, being aggrieved by the ITAT's order dated 18th August 2017 for Assessment Year 2012-2013, wherein the ITAT had allowed the assessee's appeal. Per the source preview, the assessee had filed a return of income for Assessment Year 2012-2013 declaring a loss of Rs. 4,61,48,833/- under the normal provisions of the Act, and had adopted the Resale Price Method for its transfer pricing analysis; the substantive outcome of the High Court appeal is not specified in the available source data.

8. Greaves Cotton Ltd, Mumbai vs Asst CIT Cir 7(1)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 25 July 2023
Sections engaged: 92C(3), 92F(ii), 35
Outcome: Outcome not specified in source
Procedural / substantive ground: Four appeals were filed by Greaves Cotton Limited for Assessment Years 2011-12 to 2014-15 (ITA No. 1745/MUM/2016, ITA No. 2069/MUM/2017, ITA No. 7166/MUM/2017, and ITA No. 6560/MUM/2018, PAN: AAACG2062M), involving similar grounds of appeal. Per the source preview, both parties argued the appeal for AY 2011-12 and confirmed that similar arguments applied to the other assessment years, with facts and circumstances stated to be common across the years. The substantive outcome is not specified in the available source data.

9. M/S Dell International Services India vs Additional Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 20 January 2023
Sections engaged: 92C(3), 144C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT(TP)A No.2835/Bang/2017, Assessment Year 2013-2014, PAN: AAACH1925Q) was heard on 13.01.2023 and pronounced on 20.01.2023. The source preview discloses that the transactions under examination included a manufacturing segment (Rs. 307,69,14,132), technical services provided to AEs (Rs. 3,08,20,552), marketing service charges receivable from AEs (Rs. 1,28,28,101), and warranty charges received/receivable from Dell India (Rs. 141,37,00,000), with the total at Rs. 453,42,62,785. A comparable benchmarking table for the manufacturing segment is also reproduced in the preview. The substantive outcome is not specified in the available source data.

10. Doosan Power Systems India Private vs ITO, Corporate Ward - 1(4), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 17 March 2022
Sections engaged: 92C(3), 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (IT(TP)A No. 02/Chny/2020, Assessment Year 2015-16, PAN: AABCB 5946J) was heard on 09.03.2022 and pronounced on 17.03.2022. Per the source preview, the order addresses transfer pricing comparables including objections raised by the assessee to the inclusion of Larsen and Toubro Ltd, with the assessee contending that L&T was a giant company in comparison to the assessee. Operating income, operating expenses, and operating profit figures are also recorded in the preview. The substantive outcome is not specified in the available source data.

11. Adp Private Limited (31/10/2015) vs DCIT, Circle-1( 1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 3 February 2022
Sections engaged: 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 227 & 228/H/2021, Assessment Year 2016-17, PAN: AANCA8983A) were heard on 10/12/2021 and pronounced on 03/02/2022. The source preview records rival submissions being considered and references a finding in a cited decision that a particular company was held to be functionally different and engaged in diversified activities. The substantive outcome of these appeals is not specified in the available source data.

12. Infor (India) Private Limited vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 6 October 2021
Sections engaged: 92C(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This assessee's appeal (I.T.A-TP. No. 198/HYD/2021, Assessment Year 2016-17, PAN: AAACB6197Q) arose against the National E-Assessment Centre, Delhi's assessment dated 31-03-2021, framed pursuant to the Dispute Resolution Panel (DRP)-1, Bengaluru's directions dated 09-02-2021 in F.No.55/DRP-1/BNG/2019-20. Per the source preview, the TPO and the AO under the DRP's directions were alleged to have erred in making an addition to the appellant's total income of INR 26,07,96,022 based on the provisions of Chapter X of the Income Tax Act, 1961. The substantive outcome is not specified in the available source data.

Patterns across these 12 rulings

Consistent engagement of Section 92C(3) with transfer pricing machinery provisions. Across multiple cases in this set — including cases involving DRP directions and faceless assessment — Section 92C(3) is engaged alongside other transfer pricing procedural provisions. Several cases in the source data reflect the interplay between the TPO's determination, DRP directions, and the final assessment order, with the ITAT being approached after exhausting earlier appellate stages.
Comparable selection and benchmarking analysis as a recurring flashpoint. The source previews for several cases (including those relating to Sresta Natural Bioproducts, Doosan Power Systems, Dell International Services, and American Express Banking Corporation) indicate that the comparability of selected companies — including the application of filters and the functional comparability of proposed comparables — is a core ground of dispute. The assessee in the Sresta Natural Bioproducts case specifically challenged the AO's rejection of its TP documentation and benchmarking analysis as being based on inappropriate or unreasonable grounds.
Revenue appeals following CIT(A) relief. The Viney Corporation case reflects a pattern where the Revenue files an appeal before the ITAT after the Commissioner of Income-tax (Appeals) has ruled in the assessee's favour, indicating that Section 92C(3) disputes frequently involve multiple appellate tiers before reaching finality.
Multi-year consolidation of similar transfer pricing grounds. The Greaves Cotton case involves four assessment years (AY 2011-12 to AY 2014-15) heard together before the ITAT Mumbai, with both parties confirming that similar arguments applied across all years. This reflects a common litigation pattern in transfer pricing matters where methodological and comparability disputes recur across consecutive assessment years for the same taxpayer.
Geographic spread of benches. The 12 rulings are distributed across ITAT benches in Delhi, Chennai, Hyderabad, Mumbai, and Bangalore, as well as the Delhi High Court and the Bombay High Court, indicating that Section 92C(3) litigation is geographically widespread and not concentrated in any single jurisdiction within India.

How to use this compilation

This compilation is organised as a first-pass research index. Each entry provides the key identity fields — tribunal/court, bench, date of pronouncement, sections engaged, and outcome direction — drawn directly from the source data, together with a brief procedural note drawn from the available text preview of each order. Researchers should treat this index as a finding aid, not as a substitute for reading the full judgment. Many of the orders listed here involve extensive fact-specific analysis of comparables, functional profiles, and economic data that cannot be adequately summarised from a text preview alone.

Before relying on any ruling listed in this index for any purpose, researchers should: (i) locate and read the full text of the original order from the official court portal (indiankanoon.org, the ITAT's official website, or the relevant High Court portal); (ii) check whether the order has been stayed, reversed, or modified in subsequent proceedings before a higher forum, including the relevant High Court or the Supreme Court of India; and (iii) verify whether any CBDT circular, instruction, or notification has been issued that may be relevant to the legal position discussed in the ruling.

Transfer pricing law under Chapter X of the Income Tax Act, 1961 is a highly fact-sensitive area. The outcome in any given case will depend on the specific transactional facts, the functional and economic profile of the taxpayer, the comparables selected, the method applied, and the documentation maintained under the relevant rules. Researchers should also consider checking for any relevant Safe Harbour Rules notifications or Advance Pricing Agreement (APA) guidance that may be applicable to the transaction types featured in the rulings indexed above.

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(3) Transfer Pricing Adjustments: 12 ITAT & HC Rulings (2021–2026)