This compilation indexes twelve High Court rulings from March 2025 to May 2026 in which Section 92C of the Income Tax Act, 1961 — the core provision governing the computation of arm's length price in transfer pricing — was among the sections engaged. The cases span the Delhi, Bombay, Karnataka, and Gujarat High Courts and touch on a range of connected issues: comparable selection by Transfer Pricing Officers, references to TPOs under Section 92CA, reassessment proceedings involving transfer pricing adjustments, the Dispute Resolution Panel process under Section 144C, and penalty proceedings under Section 270A arising from transfer pricing additions. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, court-by-court reference index for preliminary research.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal or tax advice. Readers must verify every ruling against the full judgment text and check for subsequent stays, reversals, or appeals before relying on any entry.

The statutory framework in one paragraph

Section 92C of the Income Tax Act, 1961 prescribes the method for computation of arm's length price (ALP) in respect of international transactions between associated enterprises. Sub-section (1) provides that the ALP shall be determined by any of the prescribed methods — being the comparable uncontrolled price method, resale price method, cost plus method, profit split method, transactional net margin method, or such other method as may be prescribed — having regard to the nature of the transaction and the class of associated enterprises and transactions. Sub-section (2) provides that where more than one price is determined by the prescribed method, the arm's length price shall be taken to be the arithmetical mean of such prices, subject to a tolerance band as may be notified. Sub-section (3) empowers the Assessing Officer to determine the ALP if he is of the opinion that the ALP declared by the assessee is not in accordance with the provisions of the section. The section operates within Chapter X of the Act, which governs special provisions relating to avoidance of tax through transfer pricing.

The 12 rulings

1. Pr. Commissioner Of Income Tax - 1 vs M/S. American Express (India) Pvt. Ltd

Bench: Delhi High Court
Date: 18 May 2026
Sections engaged: 92C, 10A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Delhi High Court as ITA 656/2019 by the Principal Commissioner of Income Tax against the respondent. The source preview indicates the dispute involved comparable company selection in a transfer pricing matter, with the text showing a set of companies and their operating profit to operating cost ratios considered by the TPO, alongside inclusion and exclusion decisions for certain comparables; one proposed question of law noted in the preview was whether the ITAT erred in directing the TPO to include a particular comparable without considering a prior decision of the Delhi High Court.

2. Sandoz Ag vs Deputy Commissioner Of Income Tax

Bench: Bombay High Court
Date: 25 March 2026
Sections engaged: 56(2)(x), 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 3862 of 2026) was filed before the Bombay High Court seeking to quash an order dated 28 January 2026 passed by the respondent, a reference purportedly made to the Transfer Pricing Officer under Section 92CA(1), and a show cause notice dated 14 January 2026. Per the source preview, the respondent rejected the assessee's objections to the TPO reference for Assessment Year 2024-25, and the main ground of challenge raised in the petition was that Chapter X of the Income Tax Act, 1961 had been invoked without satisfying a threshold condition.

3. Archroma International (India) vs Deputy Commissioner Of Income Tax

Bench: Bombay High Court
Date: 22 December 2025
Sections engaged: 143(2), 144C, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(L) No. 11219 of 2025) was filed before the Bombay High Court under Article 226 of the Constitution of India in respect of Assessment Year 2009-10, challenging the inaction of the respondents as described in the petition. Per the source preview, the court was informed during hearing that a rectification application dated 14 June 2016 had been disposed of by order dated 15 September 2025, resulting in a refund of Rs. 4,17,04,918/- credited to the petitioner's bank account on 18 December 2025; the petitioner stated it was not able to verify the correctness of the refund amount at that stage.

4. Essilor India Pvt Ltd vs The Deputy Commissioner

Bench: Karnataka High Court
Date: 15 October 2025
Sections engaged: 147, 148, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 3410 of 2020) was filed before the Karnataka High Court under Article 226 of the Constitution of India praying to quash an order dated 08.11.2019 passed by the first respondent rejecting the petitioner's objections to the reopening of assessment. Per the source preview, the petitioner challenged the reopening proceedings, with the matter involving transfer pricing-related respondents including an Assistant Commissioner of Income Tax (Transfer Pricing) among the named respondents.

5. Man Truck And Bus India Private Limited vs The Assessment Unit Income Tax Dept. And

Bench: Bombay High Court
Date: 9 September 2025
Sections engaged: 270A, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 5437 of 2025) was filed before the Bombay High Court seeking to quash a penalty order dated 24 March 2025 imposing penalty under Section 270A for Assessment Year 2017-18. Per the source preview, the petitioner had filed its return of income on 30 November 2017 declaring income as "NIL" after set-off of brought forward loss of Rs. 17.14 Crores, the case was selected for scrutiny, and assessment proceedings were completed with an order passed on 24 June 2021.

6. The Pr Commissioner Of Income Tax-1 vs Robert Bosch Engineering And Business

Bench: Karnataka High Court
Date: 20 August 2025
Sections engaged: 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The income tax appeal (ITA No. 145 of 2025) was filed before the Karnataka High Court under Section 260A of the Income Tax Act, 1961 praying to allow the appeal and set aside the order passed by the Income Tax Appellate Tribunal, Bangalore in IT(TP)A No. 446/BANG/2020 dated 09.12.2024 for Assessment Year 2012-2013, which had confirmed the order of the Appellate Commissioner and confirmed the order passed by the Assessing Officer, Circle-2(1)(1), Bengaluru.

7. Tech Mahindra Limited 2022 23 vs Assistant Commissioner Of Income Tax

Bench: Bombay High Court
Date: 19 August 2025
Sections engaged: 92, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(L) No. 19289 of 2025) was filed before the Bombay High Court challenging an order dated 2 April 2025 passed by the first respondent for Assessment Year 2022-23, which rejected the petitioner's applications dated 5 February 2025 and 14 February 2025 filed for rectifying mistakes apparent from the record in the transfer pricing order dated 28 January 2025 passed under Section 92CA. Per the source preview, the petitioner is engaged in providing IT and ITeS services with 90% of revenue from exports and at times sub-contracts work to its subsidiaries.

8. Man Truck And Bus India Private Limited vs The Assessment Unit Income Tax Dept. And

Bench: Bombay High Court
Date: 18 August 2025
Sections engaged: 270A, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 5437 of 2025) was filed before the Bombay High Court seeking to quash the penalty imposed under Section 270A for Assessment Year 2017-2018. Per the source preview, the petitioner had filed its return of income on 30 November 2017 declaring income as 'NIL' after set-off of brought forward loss of Rs. 17.14 Crores; assessment proceedings were completed and an order was passed on 24 June 2021 under Section 143(3) read with Section 144C(3), under which an addition of Rs. 31.15 Crores on account of a Transfer Pricing Adjustment was made, following which the petitioner preferred an appeal before the CIT (Appeals).

9. Weatherford Drilling And Production vs Deputy Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 5 August 2025
Sections engaged: 143(3), 147, 148, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The special civil application (R/SCA No. 6393 of 2022) was filed before the Gujarat High Court at Ahmedabad. Per the source preview, the matter was taken up for hearing with the consent of the learned advocates for the respective parties given that the controversy arose in a narrow compass; the court noted Rule returnable forthwith with the learned Senior Standing Counsel waiving service of notice of rule on behalf of the respondents.

10. 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 income tax appeal (ITA 5/2025) was filed before the Delhi High Court. Per the source preview, the dispute involved transfer pricing adjustments made by the TPO in respect of international transactions including provision of IT enabled services and intra-group services for the relevant assessment year, with the TPO determining adjustments under Section 92CA; the preview also sets out the TPO's remarks on various comparability filters applied during the benchmarking analysis.

11. Infrrd Private Limited vs Assessment Unit

Bench: Karnataka High Court
Date: 16 April 2025
Sections engaged: 144C, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 11367 of 2025) was filed before the Karnataka High Court under Article 226 of the Constitution of India praying to quash an order dated 20.03.2025 bearing DIN ITBA/AST/S/143(3)/2024-25/1074765838(1) issued by the first respondent (Assessment Unit, National Faceless Assessment Centre) for Assessment Year 2022-23. The matter was listed for preliminary hearing per the source preview.

12. The Principal Commissioner Of Income vs M/S Bosch Rexroth (India) Ltd

Bench: Gujarat High Court
Date: 25 March 2025
Sections engaged: 143(2), 143(3), 144C(1), 144C(13), 254(2), 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The special civil application (R/SCA No. 14656 of 2024) was filed before the Gujarat High Court under Article 226 of the Constitution of India challenging an order dated 24.01.2024 passed by the Income Tax Appellate Tribunal, "D" Bench, Ahmedabad in Misc. Application No. 85/Ahd/2023 in IT(TP)A No. 930/Ahd/2015 for Assessment Year 2010-11. Per the source preview, the assessee had selected the option of raising objections before the Dispute Resolution Panel against the draft order, and the Assessing Officer thereafter passed an assessment order dated 12.02.2015.

Patterns across these 12 rulings

Writ jurisdiction as a primary challenge route. Across multiple cases in this compilation — including cases from the Bombay and Karnataka High Courts — taxpayers have approached the High Courts under Article 226 of the Constitution of India to challenge transfer pricing-related orders and inaction, rather than exhausting the statutory appellate ladder alone. This reflects a pattern of seeking writ intervention at intermediate procedural stages.
TPO reference process as a standalone ground of challenge. At least two cases (cases 2 and 7 per the source previews) involve direct challenges to the process of making or declining to rectify a reference to the Transfer Pricing Officer, suggesting that the procedural conditions for invoking the TPO mechanism under Chapter X are a recurring battleground before the High Courts.
Intersection of transfer pricing adjustments and penalty proceedings. Cases 5 and 8 in this compilation involve the same petitioner challenging a penalty imposed under Section 270A arising from a transfer pricing addition, illustrating that transfer pricing disputes frequently generate downstream penalty litigation as a second wave of proceedings after the primary assessment.
Comparable selection disputes reaching High Courts on appeal. Cases 1 and 10 involve ITA-route appeals before the Delhi High Court in which the correctness of the TPO's or ITAT's comparable selection and benchmarking analysis — including the application of filters and determination of adjustments — appears to be the substantive question, reflecting the continued frequency of this issue reaching appellate courts.
Reassessment proceedings in a transfer pricing context. Cases 4 and 9 involve petitions or applications in which provisions governing reassessment appear alongside Section 92C, indicating a pattern of taxpayers challenging the validity of reopening proceedings where transfer pricing was a basis or consequence of the original or reopened assessment.

How to use this compilation

This compilation is a starting-point index, not a substitute for reading the full judgment in each case. Each entry in the rulings section above is grounded only in the source preview and identity fields available in the TaxNoticeAI structured corpus. Where the source preview is limited to procedural recitals or caption-level information, the substantive holding of the court is not summarised here; researchers must retrieve and read the complete judgment from indiankanoon.org or the relevant official court portal before drawing any conclusion about the ratio or outcome of the case.

Before relying on any ruling for a research note, client advice, or litigation strategy, researchers should verify: (a) whether the judgment has been stayed by a higher court; (b) whether an appeal or special leave petition has been filed and is pending; (c) whether the ruling has been affirmed, reversed, or distinguished in a subsequent judgment; and (d) whether any relevant CBDT circular, instruction, or notification has been issued that affects the interpretation of the sections engaged. Transfer pricing law in India is also subject to ongoing amendments to the rules prescribing the methods and tolerance bands under Section 92C, and the applicable rules for a given assessment year should be checked independently.

Researchers using this index for multi-year or cross-court pattern analysis should note that the cases span different assessment years and different High Courts, and that the precedential weight of a High Court ruling is ordinarily limited to the jurisdiction of that court unless affirmed by the Supreme Court of India or adopted by other benches. Parallel ITAT rulings on comparable fact patterns may also be relevant and are not captured in this High Court-specific compilation.

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 Transfer Pricing: 12 High Court Rulings (2025–2026)