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151 results for “disallowance”+ Section 92Bclear

Sorted by relevance

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Key Topics

Section 143(3)92Transfer Pricing67Section 92C61Addition to Income50Comparables/TP42Section 10A36Disallowance33Section 144C24Section 15422

NOVO NORDISK INDIA PRIVATE LIMITED vs. DCIT, BANGALORE

In the result the appeal of the Assessee is partly allowed

ITA 146/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Jul 2015AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Abraham P.George

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri R. Ravichandran, CIT-III (DR)
Section 143(3)Section 144CSection 92ASection 92E

Section 92B(2) by the Finance Act, 2014 was inserted only by way of abundant caution. It is made with a view to clarify the position that by entering into series of transactions with third parties who are not associated enterprises or non- residents, one cannot claim that the Transfer Pricing regulations were not applicable, if in reality

Showing 1–20 of 151 · Page 1 of 8

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TP Method20
Section 144C(5)15
Section 14A15

SASKEN TECHNOLOGIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 404/BANG/2017[2012-13]Status: DisposedITAT Bangalore30 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 404/Bang/2017 Assessment Year : 2012-13 M/S. Sasken Technologies Ltd., (Formerly Known As The Deputy Sasken Communication Commissioner Of Technologies Ltd.), Income Tax, No. 139/25, Domlur Circle – 6(1)(1), Ring Road, Vs. Bangalore. Bangalore – 560 071. Pan: Aaecs6424R Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca : Shri K. Sankar Ganesh, Jcit Revenue By Dr Itat Date Of Hearing : 15-11-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Assessment Order Dated 31.01.2017 Passed By Ld.Dcit, Circle – 6(1)(1), Bangalore For A.Y. 2012-13 On Following Concise Grounds Of Appeal: “1. General:- The Learned Ao & The Drp Erred In Passing The Order / Directions In The Manner Passed By Them. The Orders Passed Being Bad In Law Is Liable To Be Quashed.

For Respondent: Shri Padam Chand Khincha
Section 133(6)Section 2(24)Section 92BSection 92C

92B of the IT Act. (iii) determining / confirming the adjustment of Rs. 275,238/- under section 92CA in respect of the corporate guarantee given to Sasken OY (iv) computing adjustment under section 92CA at 0.925% of the corporate guarantee amount given to Sasken OY; (v) using the information obtained from M/s CRISIL Ltd under section 133(6) for the purpose

IBM INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal by the assessee stands allowed as indicated hereinabove

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR
Section 10ASection 143(3)Section 144BSection 144C(13)

disallowing the said expense without giving cognizance to the facts of the Appellant and the various judicial precedents relied on by the Appellant. 7.4. The Hon'ble DRP has erred on facts and in law in holding that ESOP/ Employee Share Based Plan (`ESBP') expense does not satisfy conditions of section

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

section 92B of the Act by way of Finance Act, 2012 with retrospective effect from 01/04/2002 that, the interest on outstanding receivables is an international transaction, and it certainly requires separate benchmarking. 24.1 Now, coming to the issue in respect of the rate of interest, we find relevant to refer the judgment of Hon'ble Bombay High Court

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 1600/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

GMR INFRASTRUCTURE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 1599/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. M/S GMR INFRASTRUCTURE LTD , BANGALORE

In the result, Ground no. 1 raised for A

ITA 1741/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

ITA 1743/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

GMR HIGHWAYS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE- 3(1)(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 495/BANG/2020[2016-17]Status: DisposedITAT Bangalore25 May 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

ITA 1742/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

GMR HIGHWAYS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 1643/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 1622/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

ITA 1705/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

ITA 1744/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered

ITO, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 402/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

disallowances for computing section 10A deduction for Bangalore BPO unit. It was submitted that the assessee has submitted a rectification application seeking relief provided by the DRP. The AO has issued rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 556/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

disallowances for computing section 10A deduction for Bangalore BPO unit. It was submitted that the assessee has submitted a rectification application seeking relief provided by the DRP. The AO has issued rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11

DCIT, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 459/BANG/2015[2010-11]Status: DisposedITAT Bangalore19 Jan 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

disallowances for computing section 10A deduction for Bangalore BPO unit. It was submitted that the assessee has submitted a rectification application seeking relief provided by the DRP. The AO has issued rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 492/BANG/2015[2010-11]Status: DisposedITAT Bangalore19 Jan 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

disallowances for computing section 10A deduction for Bangalore BPO unit. It was submitted that the assessee has submitted a rectification application seeking relief provided by the DRP. The AO has issued rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11

M/S. IBM INDIA PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 4, BANGALORE

In the result, appeal by the assessee for A

ITA 1016/BANG/2019[2014-15]Status: DisposedITAT Bangalore14 Feb 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 625/Bang/2017 Assessment Year : 2012-13 M/S. Ibm India Pvt. Ltd., The Assistant No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent & It(Tp)A No. 1016/Bang/2019 Assessment Year : 2014-15 M/S. Ibm India Pvt. Ltd., The Joint No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Special Range-4, Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca : Shri K.V. Arvind, Standing Revenue By Counsel Date Of Hearing : 03-02-2022 Date Of Pronouncement : 14-02-2022

For Appellant: Shri Ajay Roti, CA
Section 10ASection 143(3)Section 144C(13)

disallowance under section 14A stands deleted. Accordingly this ground raised by assessee stands allowed.” Admittedly for year under consideration 11. Ground nos. 12 to 14 (A.Y. 2012-13) are consequential in nature. Page 15 of 21 IT(TP)A Nos. 625/Bang/2017 & 1016/Bang/2019 Accordingly the appeal filed by the assessee for Assessment Year 2012-13 stands allowed as indicated hereinabove

M/S. IBM INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, appeal by the assessee for A

ITA 625/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Feb 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 625/Bang/2017 Assessment Year : 2012-13 M/S. Ibm India Pvt. Ltd., The Assistant No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent & It(Tp)A No. 1016/Bang/2019 Assessment Year : 2014-15 M/S. Ibm India Pvt. Ltd., The Joint No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Special Range-4, Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca : Shri K.V. Arvind, Standing Revenue By Counsel Date Of Hearing : 03-02-2022 Date Of Pronouncement : 14-02-2022

For Appellant: Shri Ajay Roti, CA
Section 10ASection 143(3)Section 144C(13)

disallowance under section 14A stands deleted. Accordingly this ground raised by assessee stands allowed.” Admittedly for year under consideration 11. Ground nos. 12 to 14 (A.Y. 2012-13) are consequential in nature. Page 15 of 21 IT(TP)A Nos. 625/Bang/2017 & 1016/Bang/2019 Accordingly the appeal filed by the assessee for Assessment Year 2012-13 stands allowed as indicated hereinabove