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27 results for “transfer pricing”+ Section 153Bclear

Sorted by relevance

Mumbai67Cochin59Hyderabad46Delhi31Bangalore27Chennai26Ahmedabad24Jaipur20Guwahati18Chandigarh12Nagpur6Pune6Lucknow5Kolkata4Visakhapatnam3Indore1Panaji1Rajkot1Surat1Dehradun1

Key Topics

Section 132(4)28Section 69B25Section 153A21Addition to Income21Section 13217Section 25012Section 143(3)10Section 92C10Section 153C

DY.COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2),, AHMEDABAD vs. M/S.QUINTILES RESEARCH INDIA PVT.LTD.,, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the departmental appeal is dismissed

ITA 946/AHD/2016[2011-12]Status: DisposedITAT Bangalore10 Dec 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2011-12

For Appellant: Shri Ketan Ved, CAFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 153Section 153BSection 92C

transfer price and the assessment in cases involving international transactions,it has been proposed to revise the time limits specified in sections 153 and 153B

Showing 1–20 of 27 · Page 1 of 2

10
Disallowance6
Limitation/Time-bar5
Transfer Pricing3

QUINTILES RESEARCH (INDIA) PVT. LTD.,BANGALORE vs. THE DY.CIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the\ndepartmental appeal is dismissed

ITA 1025/AHD/2016[2011-12]Status: DisposedITAT Bangalore10 Dec 2025AY 2011-12
Section 143(3)Section 153Section 92C

Transfer Pricing adjustment was quashed.", "result": "Partly Allowed", "sections": [ "143(3)", "144C", "153", "153B", "92CA", "92CA(3)", "92CA(3A)", "92C" ], "issues

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

ITA 1844/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, A.RFor Respondent: Dr. Divya K.J., D.R
Section 143(3)

Transfer Pricing Officer passed order under Section 92CA of IT Act on 30.01.2015 for the assessment year 2011-12. Subsequently, the respondent-Revenue passed draft assessment order under Section 144C read with Section 143(2) of the IT Act on 27.03.2015. Against the said draft assessment order, appellant filed objections/appeal before the DRP and the DRP after hearing, passed order

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

ITA 1297/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Aug 2024AY 2017-18
Section 139(9)Section 143(2)Section 153CSection 250Section 45

price for the deficit area at mutually agreed\nrates. The payment for such area, if any, by First Party or Second Party shall\nbe paid on completion of construction of the building and delivery of\nOWNERS' AREA' in the building and vice-versa.\nThe First Party and/or their nominee/s and/or their assignee/s and\nSecond Party and Second Party's aforesaid

MICROSOFT RESEARCH LAB INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(1)(1), BENGALURU

In the result, the appeal is set aside for doing it denovo

ITA 1842/BANG/2024[AY 2017-18]Status: DisposedITAT Bangalore28 Nov 2025

Bench: Ms. Padmavathy S. & Shri Rahul Chaudhary

For Appellant: Sri Nageshwar RaoFor Respondent: Dr. Divya K.J
Section 143(3)Section 144BSection 144CSection 144C(2)Section 144C(3)Section 153Section 153BSection 250

153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,- Page 2 of 7 IT(TP)A No.1842/Bang/2024 Assessment Year 2017-2018 (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires.” 5. Bare perusal of the above shows that under Section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, HUBBALLI vs. SMT. SHEELA PRASANNAKUMAR , CHITRADURGA

In the result, the appeals of the Revenue are dismissed

ITA 1464/BANG/2024[2018-19]Status: DisposedITAT Bangalore20 Dec 2024AY 2018-19
Section 132Section 153BSection 56(2)(x)

153B of the Act were applicable in the case of\nthe assessee and the case was selected for scrutiny and notice under section\n143(2) of the Act was issued to the assessee on 23.09.2019 and other\nstatutory notices were issued to the assessee. The authorized representative\nof the assessee appeared and attended the case and filed submissions as\ncalled

MOHAMMED ABDUL NAJEEB,GULBARGA, KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

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

ITA 1175/BANG/2024[2012-13]Status: DisposedITAT Bangalore29 Aug 2025AY 2012-13
Section 127Section 131(1)(d)Section 142ASection 143(3)Section 153ASection 153D

153B as the appellant was issued\nnotice under Section 153A of the Act.\n8. On facts and circumstances of the\nAppellants case, the learned assessing\nofficer is not justified in passing the\nassessment order in gross violation of\nprinciples of natural justice in as much as\nthe learned assessing officer did not afford,\nin specific and particularly, any\nopportunity

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, HUBBALLI vs. SRI LINGARAJU GOWDARA MALLIKARJUNAPPA, CHITRADURGA

ITA 1463/BANG/2024[2018-19]Status: DisposedITAT Bangalore20 Dec 2024AY 2018-19
Section 132Section 153B

153B of the Act were applicable in the case of\nthe assessee and the case was selected for scrutiny and notice under section\n143(2) of the Act was issued to the assessee on 23.09.2019 and other\nstatutory notices were issued to the assessee. The authorized representative\nof the assessee appeared and attended the case and filed submissions as\ncalled

NIYAZ SEA FOODS ,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1 , MANGALORE

In the result, appeal of the assessee in ITA

ITA 1019/BANG/2024[2018-19]Status: DisposedITAT Bangalore12 Aug 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal, A.RFor Respondent: Shri V. Parithivel, D.R
Section 132Section 133ASection 143Section 143(3)Section 153ASection 153CSection 2Section 41Section 41(1)

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

M/S. HARIS MARINE PRODUCTS,MANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALORE

In the result, both the appeals of the assessee are\nallowed

ITA 610/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17
Section 132Section 133ASection 153C

transfer of properties”.\n5.18. The Hon'ble Supreme Court in the case of K.P. Varghese vs.\nITO (1981) 131 ITR 597 (SC) held that the capital gains is intended\nto tax the gains of assessee not what an assessee might have gained\nand what is not gained cannot be computed as gain and the\nassessee cannot fastened with the liability

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeal of the assessee in ITA

ITA 463/BANG/2024[2014-15]Status: DisposedITAT Bangalore08 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

transfer of properties”. 4.34 The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, MANGALORE

In the result, appeal of the assessee in ITA

ITA 464/BANG/2024[2015-16]Status: DisposedITAT Bangalore08 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

transfer of properties”. 4.34 The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , MANGALORE

In the result, appeal of the assessee in ITA

ITA 466/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

transfer of properties”. 4.34 The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

MOHAMMED IBRABIM MOHIDEEN ,KERALA vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALURU

In the result, appeal of the assessee in ITA

ITA 486/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

transfer of properties”. 4.34 The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

MOHAMMED IBRAHIM MOHIDEEN,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeal of the assessee in ITA\nNo

ITA 465/BANG/2024[2016-17]Status: DisposedITAT Bangalore08 Jul 2024AY 2016-17
Section 153ASection 69B

transfer of properties”.\n4.34 The Hon'ble Supreme Court in the case of K.P. Varghese vs.\nITO (1981) 131 ITR 597 (SC) held that the capital gains is intended\nto tax the gains of assessee not what an assessee might have gained\nand what is not gained cannot be computed as gain and the\nassessee cannot fastened with the liability

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 836/BANG/2024[2018-19]Status: DisposedITAT Bangalore12 Jun 2024AY 2018-19
Section 115BSection 132Section 132(4)Section 234A

153B and 153C contemplate a merger of regular\nassessments with those that may be triggered by a search. On a\nsearch being undertaken in terms of Section 153A, the\njurisdictional AO is enabled to initiate an assessment or\nreassessment, as the case may be, in respect of the six AYs'\nimmediately preceding the AY relevant to the year of search

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 835/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Jun 2024AY 2014-15
For Appellant: Shri V. Srinivasan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132Section 132(4)Section 234ASection 69A

153B and 153C contemplate a merger of regular\nassessments with those that may be triggered by a search. On a\nsearch being undertaken in terms of Section 153A, the\njurisdictional AO is enabled to initiate an assessment or\nreassessment, as the case may be, in respect of the six AYs'\nimmediately preceding the AY relevant to the year of search

M/S. EMIRATES HINDUSTAN BUILDERS AND DEVELOPERS,KERALA vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 415/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R
Section 132(4)Section 143(3)Section 148Section 68

transfer of properties”. 8.12. The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

MKH INFRASTRUCTURE,KERALA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 174/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R
Section 132(4)Section 143(3)Section 148Section 68

transfer of properties”. 8.12. The Hon’ble Supreme Court in the case of K.P. Varghese vs. ITO (1981) 131 ITR 597 (SC) held that the capital gains is intended to tax the gains of assessee not what an assessee might have gained and what is not gained cannot be computed as gain and the assessee cannot fastened with the liability

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

ITA 434/BANG/2024[2016-17]Status: DisposedITAT Bangalore03 Jul 2024AY 2016-17
Section 132Section 132(4)Section 153ASection 153DSection 234A

transfer of money, but the\nTribunal rightly held that there were independent transactions\nand had nothing to do with the MOU. On the basis of aforesaid,\nit was held that no substantial question of law arises.\n5.23 The case of ld. Counsel was that there should be some\ntangible material on record to show that the purchases were not\nmade