BharatTax.net
SearchITATHigh CourtsSupreme CourtAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

8 results for “transfer pricing”+ Section 148Aclear

Sorted by relevance

Mumbai51Jaipur22Delhi21Bangalore8Chennai7Chandigarh7Kolkata5Agra5Pune4Rajkot4Hyderabad2Indore2Guwahati1Nagpur1Amritsar1Ahmedabad1Visakhapatnam1

Key Topics

Section 14719Section 14817Section 5412Section 697Section 148A6Section 144C5Reopening of Assessment5Section 115B4Section 56(2)4Deduction

VAZHOOR SUDARSANAN THAMPI,THRISSUR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), WARD-2(1), BENGALURU

Appeal is partly allowed

ITA 893/BANG/2025[2015-16]Status: DisposedITAT Bangalore28 Aug 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan Ka. Y. 2015-16 Appellant Respondent Vazhoor Sudarshanan The Income Tax Officer Thampi International Taxation Vazhoor House, Ward 2 (1) T C 5/1892Valappad Bangalore Vallapad Beach Thrissur Kerala 680567 Pan Afxpt6193D For Appellant Shri Sidhesh N Gadi, Ca For Respondent Dr. Divya K J Cit Dr Date Of Hearing 19-08-2025 Date Of Pronouncement 28-08-2025

Section 142Section 143Section 144Section 144CSection 147Section 148Section 148ASection 69

148A (d) of the act was passed on 19/4/2022 and accordingly notice under section 148 of the act was issued on 19/4/2022. Assessee failed to respond. Further ld AO issued notice under section 142 (1) through the ITBA portal on various dates but same was not responded to. Accordingly, the learned assessing officer proceeded to pass a draft assessment order

3
Addition to Income3
Double Taxation/DTAA2

HEWLETT-PACKARD (INDIA) SOFTWARE OPERATION PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-(1)(1) , BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 405/BANG/2024[2014-15]Status: DisposedITAT Bangalore09 Jan 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2014-15

For Appellant: Sri P.C. Kincha, A.RFor Respondent: Sri A. Sreenivasa Rao, D.R
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 250Section 92C

transfer pricing adjustment and thereafter the draft assessment order was issued on 26.12.2017. The company filed a review application before ld. DRP on 25.1.2018 against the draft assessment order. The ld. DRP issued its direction vide an order dated 14.9.2018. The TPO accordingly issued an order giving effect to ld. DRP’s direction. Finally, the assessment proceedings

M/S. STEER AMERICA INC., ,UNITED STATES vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION CIRCLE -1(2) , BENGALURU

In the result, both the appeals of the assessee are partly allowed

ITA 832/BANG/2024[2013-14]Status: DisposedITAT Bangalore10 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

transfer of a technical plan or technical design to such person, (For this purpose, the person acquiring the service shall be deemed to include an agent nominee, or transferee of such person.) This category is narrower than the category described in paragraph 4(a) because it excludes any service that does not make technology available to the person acquiring

M/S. STEER AMERICA INC.,,UNITED STATES vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION CIRCLE -1(2), BENGALURU

In the result, both the appeals of the assessee are partly allowed

ITA 833/BANG/2024[2014-15]Status: DisposedITAT Bangalore10 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R
Section 144CSection 147Section 148

transfer of a technical plan or technical design to such person, (For this purpose, the person acquiring the service shall be deemed to include an agent nominee, or transferee of such person.) This category is narrower than the category described in paragraph 4(a) because it excludes any service that does not make technology available to the person acquiring

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,MANGALORE, MANGALORE vs. RAJ DIAMONDS, MUMBAI

In the result the appeal of the Revenue is dismissed &

ITA 1361/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Subramanian, D.R
Section 132Section 143(1)Section 143(2)Section 144(3)Section 148Section 153CSection 250

section Date of Notice 1 148A(b) 10/03/2022 2 148A(d) 23/03/2022 3 148 23/03/2022 4 129 01/07/2022 5 143(2)* No valid Return filed by the assessee 6 142(1) 17/11/2022 7 Show Cause Notice 18/03/2023 The claim of the AO is that the assessee did not file any return of income in response to notice

INDIRA RAMAIAH ,BANGALORE vs. INCOME TAX OFFICER, WARD-1(2)(1), BANGALORE

In the result, the appeal of the assessee is dismissed

ITA 507/BANG/2024[2015-16]Status: DisposedITAT Bangalore03 Jun 2024AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2015-16

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Ms. Shamala D.D., Addl.CIT(DR)(ITAT), Bengaluru
Section 115BSection 148Section 234ASection 56(2)Section 69

148A(d) and u/s. 148 on 31.03.2022 was issued with the approval of competent authority. Thereafter the case was transferred to Faceless Unit to complete the assessment. The assessee filed return of income on 23.08.2022 in compliance of notice u/s 148 declaring total income at Rs.13,91,210 and submitted that assessee has received income from time deposits

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

ITA 258/BANG/2025[2018-19]Status: DisposedITAT Bangalore04 Nov 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

For Appellant: Sri Siddesh N Gaddi, A.RFor Respondent: Dr. Divya K.J., D.R
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 54Section 54(2)Section 80T

148A of the Act. Accordingly, notice u/s. 148 of the Act was issued to the assessee on 07/04/2022. In response to notice u/s.148 of the Act, the assessee did not file any return of Income however during the course of assessment proceedings, the assessee filed a computation of income declaring income from house property of Rs.59,535/- and interest from

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

ITA 235/BANG/2025[2016-17]Status: DisposedITAT Bangalore04 Nov 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Sri Varadarajan D.P., A.RFor Respondent: Dr. Divya K.J., D.R
Section 142(1)Section 147Section 148Section 148ASection 45Section 54

148A(d)of the Act along with the notice u/s. 148 of the Act were served to the assessee. In response to notice u/s. 148 of the Act, the assessee filed his return of income on 11/01/2024. From the return of income filed by the assessee, it was seen by the AO that the assessee had claimed cost of acquisition