This compilation indexes twelve income-tax appellate decisions — eleven from various benches of the Income Tax Appellate Tribunal and one from the Madras High Court — in which Section 92D of the Income Tax Act, 1961 was cited as a section engaged by the proceedings. The rulings span Assessment Years 2006-07 through 2022-23 and were pronounced between September 2021 and July 2026. The compilation is intended for use by in-house tax teams, Big-4 transfer pricing practitioners, and law firm researchers who need a structured, citable reference index on Section 92D litigation across multiple ITAT benches and one High Court.

Research index only. This page is a neutral case-law reference compiled from the TaxNoticeAI structured legal corpus. Nothing on this page constitutes legal or tax advice. Readers must consult the full text of each judgment and verify currency before relying on any ruling.

The statutory framework in one paragraph

Section 92D of the Income Tax Act, 1961 imposes an obligation on every person who has entered into an international transaction or a specified domestic transaction to keep and maintain prescribed information and documents in relation to such transaction. The section empowers the Assessing Officer or the Transfer Pricing Officer to require the assessee to furnish such information or documents within a specified period. Failure to maintain the prescribed documentation or to furnish it on demand engages penalty provisions elsewhere in the Act (such as Section 271G), and the existence or absence of compliant documentation is routinely examined in transfer pricing assessments. The section operates in conjunction with other provisions in Chapter X of the Act governing the arm's length pricing of international transactions and specified domestic transactions.

The 12 rulings

1. Clinchoice Private Limited,Bengaluru vs DCIT Circle 2(2)(1),Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 20 July 2026
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as IT(TP)A No. 846/BANG/2026 and pertains to Assessment Year 2022-23. Per the source preview, the matter was heard on 28 April 2026 and the order was pronounced on 20 July 2026 before the Bangalore Bench; the substantive reasoning is not reproduced in the available text preview beyond the formal cause-title and dispatch details.

2. M/S Veolia Water Technologies And vs Deputy Commissioner Of Income, Circle

Bench: Income Tax Appellate Tribunal - Delhi
Date: 15 July 2026
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals were filed as ITA No. 3780/Del/2024 (Assessment Year 2020-21) and ITA No. 5843/Del/2024 (Assessment Year 2021-22) against final assessment orders dated 29.07.2024 and 30 [date truncated in source]. Per the text preview, the proceedings involved intra-group services including what the preview identifies as "Intra Group Services" (IGS) with amounts referenced, and documentation relating to agreements with entities including SWTS SA and SLOGIA; the full substantive reasoning is not reproduced in the available preview.

3. P C Snehal Engineers Private vs DCIT, Circle 3(1)(1), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 14 July 2026
Sections engaged: 271B, 92D, 92E
Outcome: Outcome not specified in source
Procedural / substantive ground: These two appeals, ITA Nos. 1173 & 1174/AHD/2026, were filed by the assessee against separate orders of the National Faceless Appeal Centre (NFAC), Delhi, both dated 09.12.2025, for Assessment Year 2014-15, in proceedings arising under Section 271BA and Section 271G of the Income Tax Act. A delay of 35 days in filing the appeal was noted, with the assessee attributing the delay to heavy workload of the tax advisor, M/s. Jayamal Thakore & Co. (Chartered Accountant), and a condonation application was filed accordingly.

4. Dsm Shared Services India Private vs DCIT., Circle 8(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 December 2025
Sections engaged: 92D, 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 1358/Hyd/2024 for Assessment Year 2021-2022. Per the source preview, the text references a list of comparable companies in the BPO/IT-enabled services segment — including entities such as Allsec Technologies Limited, Cosmic Global Limited, and others — alongside redacted sub-section text, suggesting the matter involved a transfer pricing comparables analysis; the full dispositive reasoning is not reproduced in the available preview.

5. Sempertrans India Private vs Income-Tax Officer, Panvel

Bench: Income Tax Appellate Tribunal - Pune
Date: 14 November 2025
Sections engaged: 92C, 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, ITA No. 1778/PUN/2024 for Assessment Year 2020-21, was directed against the order dated 27.06.2024 passed by the Assessing Officer. Per the source preview, the assessee raised grounds contending that the final assessment order dated 27 June 2024 was not passed in conformity with the directions of the DRP Panel as required, thereby allegedly rendering it null and void, and also that the final assessment order was issued beyond the prescribed time limit.

6. Subex Limited, Bangalore vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 27 February 2023
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, IT(TP)A No. 948/Bang/2022 for Assessment Year 2013-14, involved international transactions including Software Development and Services, Interest on intercompany loan, Marketing and Allied Services, and Recovery of ESOP expenses. Per the source preview, the proceedings engaged questions concerning the treatment of foreign exchange fluctuation as operating or non-operating in nature for the purpose of computing the profit level indicator, with the assessee citing several prior tribunal decisions on that issue.

7. Schneider Electric Infrastructure vs The Add./Jt. DCIT/ITO Natonal

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 7 December 2022
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, ITA No. 64/Ahd/2022 for Assessment Year 2017-18, concerned Schneider Electric Infrastructure Limited, characterised in the source preview as a licensed manufacturer that procures raw materials and components for the manufacture of power distribution and automation equipment, pays royalty for manufacturing intangibles, and bears inventory and pricing risk. Per the text preview, the proceedings involved a functional and characterisation analysis of the assessee's transfer pricing profile.

8. Giraffe Developers Pvt. Ltd., Mumbai vs Pr. CIT - 9 , Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 25 July 2022
Sections engaged: 263, 271, 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed the appeal against the order of the Pr. Commissioner of Income Tax (Appeals)-9, Mumbai, pertaining to Assessment Year 2014-15. Per the source preview, the assessee's grounds alleged that the PCIT grossly erred in reopening the assessment under Section 263 of the Act, characterising the reopening as unfair, illegal, and void ab initio, and further contended that the PCIT erred in directing the Assessing Officer to inquire into a claim of interest on loan and bank deposits; the full disposition is not reproduced in the available preview.

9. 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 for Assessment Year 2015-16, involved a transfer pricing analysis in which the assessee contested the selection of comparables. Per the source preview, the proceedings included a corporate adjustment involving a disallowance and a comparables dispute in which Larsen & Toubro Ltd. was among the companies whose inclusion the assessee objected to on grounds of functional and size dissimilarity.

10. ACIT-2(1), Ujjain, Ujjain vs M/S Ruchi J Oil Pvt. Ltd,, Mumbai

Bench: Income Tax Appellate Tribunal - Indore
Date: 17 January 2022
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, ITA No. 82/Ind/2020 for Assessment Year 2014-15, was filed by the Revenue. Per the source preview, the proceedings involved international transactions including the issue of equity shares to Toyota Tsusho Corporation and J Oil Mills Inc, and a specified domestic transaction involving the purchase of undertakings by slump sale from Ruchi Soya Industries Limited, with all transactions benchmarked using the Other Method. The source preview notes that it was observed by the AO that the assessee had failed to keep the requisite documentation.

11. Sun Pharmaceuticals Industries Ltd vs The Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 3 September 2021
Sections engaged: 92D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, ITA No. 360/AHD/2017 for Assessment Year 2012-2013, was filed by Sun Pharmaceutical Industries Ltd. (described in the source preview as the erstwhile Ranbaxy Laboratories Limited, now merged with Sun Pharmaceutical Industries Limited). Per the source preview, the proceedings involved multiple international transactions including sales of API benchmarked using TNMM, and grounds were raised contesting the computation of disallowance under Section 14A read with Rule 8D, among other transfer pricing issues.

12. Commissioner Of Income Tax vs M/S.Ssl-Ttk Ltd

Bench: Madras High Court
Date: 5 August 2021
Sections engaged: 92D, 271G
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal, T.C.A. No. 776 of 2014, was filed by the Revenue under Section 260A of the Income Tax Act, 1961, against the order dated 15.02.2012 in I.T.A. No. 544/Mds/2011 on the file of the Income Tax Appellate Tribunal 'D' Bench, Chennai, for Assessment Year 2006-07. The appeal was admitted on 13.07.2015 on a substantial question of law. Per the source preview, the assessee, M/s. SSL-TTK Ltd., is a public limited company engaged in the manufacture of foot care and footwear products for the domestic and export markets; the specific question of law and full disposition are not reproduced in the available text preview.

Patterns across these 12 rulings

Section 92D consistently appears in transfer pricing proceedings across ITAT benches. All twelve cases indexed here are income-tax proceedings in which Section 92D was engaged, spanning ITAT benches in Bangalore, Delhi, Ahmedabad, Hyderabad, Pune, Mumbai, Chennai, and Indore, as well as the Madras High Court. This signals that documentation-related grounds under Section 92D arise across diverse taxpayer profiles and geographies.
Section 92D frequently appears alongside related transfer pricing and penalty provisions. Several cases in this compilation engage Section 92D in combination with other provisions — Section 271G (penalty for failure to furnish documents) in case 12 and case 3, Section 92C or 92C(3) in cases 5 and 9, and Section 273B in case 4. This pattern reflects the interconnected way in which documentation obligations, arm's length pricing determinations, and penalty defences are typically litigated together.
Comparables disputes and functional characterisation are recurring substantive themes. In cases 7, 9, and 4, the source previews reveal detailed engagement with the functional profile of the assessee and the selection or rejection of comparables, indicating that Section 92D documentation issues often arise in the broader context of transfer pricing adjustments where the adequacy of the taxpayer's maintained documentation is implicated.
Revenue appeals and assessee appeals both appear in the corpus. Case 10 (ACIT-2(1), Ujjain vs M/S Ruchi J Oil Pvt. Ltd.) is filed by the Revenue, and case 12 (Commissioner of Income Tax vs M/S.SSL-TTK Ltd.) is likewise a Revenue appeal. The remaining cases are assessee appeals. This indicates that Section 92D disputes arise on both sides of the litigation divide.
Outcome directions are uniformly unspecified in the available source data. Across all twelve rulings in this compilation, the structured outcome field returns "Outcome not specified in source." Researchers requiring the operative outcome of any specific ruling must access the full judgment text directly from the source portal.

How to use this compilation

This index is designed as a first-pass research tool. Each ruling entry provides the identity fields (bench, date, sections engaged, outcome direction) drawn verbatim from the TaxNoticeAI structured corpus, together with a brief procedural note drawn strictly from the available text preview. Before citing any ruling in a submission, opinion, or filing, researchers should retrieve and read the complete judgment text from indiankanoon.org, the official ITAT e-Filing portal, or the relevant High Court's judgment information system. Text previews in a structured corpus are, by design, partial extracts and do not reproduce the full reasoning, findings, or operative directions of the tribunal or court.

Researchers should also verify whether any ruling indexed here has been subjected to a stay, has been reversed or modified on further appeal to the High Court or Supreme Court, or has been distinguished in a subsequent ruling. ITAT decisions are not binding precedent on coordinate benches, and High Court decisions bind only within their territorial jurisdiction. A ruling that appears favourable or adverse in one bench's context may have been treated differently by another bench or by a superior court.

Finally, researchers examining Section 92D matters should cross-reference the applicable CBDT rules and circulars prescribing the form and content of transfer pricing documentation (including Rule 10D of the Income Tax Rules, 1962 and any subsequent amendments or clarifications), as compliance with the prescribed documentation framework is central to the merits of any Section 92D dispute. The case-law indexed here does not substitute for a review of the current regulatory framework.

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 92D Transfer Pricing Documentation: 12 ITAT & HC Rulings (2021-2026)