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823 results for “transfer pricing”+ Section 2(47)(v)clear

Sorted by relevance

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Key Topics

Addition to Income65Section 143(3)58Section 153A38Section 153C35Transfer Pricing32Section 92C29Section 14829Comparables/TP29Section 133A

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 544/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

Showing 1–20 of 823 · Page 1 of 42

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26
Section 220
Section 2(15)18
Natural Justice17

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 542/BANG/2021[2014-15]Status: DisposedITAT Bangalore07 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 543/BANG/2021[2015-16]Status: DisposedITAT Bangalore07 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

SHRI. KOLA VENKAT RAMA NAIDU,BANGALORE vs. THE COMMISSIONER OF INCOME TAX (APPEALS) - 6, BANGALORE

In the result, the appeal of the assessee is partly allowed

ITA 206/BANG/2020[2010-11]Status: DisposedITAT Bangalore05 Aug 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 133ASection 2(47)(v)Section 250

V. Srinivasan, A.R. Respondent by : Shri Sumer Singh Meena, D.R. Date of Hearing : 14.07.2022 Date of Pronouncement : 05.08.2022 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by the assessee is directed against order of the CIT(A) dated 21.11.2019. The assessee has raised following grounds of appeal:- The impugned order dated 16.11.2019 passed by the (2

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 813/BANG/2019[2014-15]Status: DisposedITAT Bangalore02 Mar 2021AY 2014-15

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

For Appellant: Sri.Padamchand Khincha, CAFor Respondent: Smt.R.Premi, JCIT-DR
Section 191Section 194Section 201Section 201(1)Section 206ASection 4

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

M/S JUPITER CAPITAL PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-11(5), BANGALORE

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

ITA 445/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Nov 2018AY 2014-15

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodiaassessment Year : 2014-15

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri D. Sudhakara Rao, CIT (DR)
Section 2(47)

V. Sarabhai Vs. CIT (supra). The same is as under. “5. Sec. 2(47) which is an inclusive definition, inter alia, provides that relinquishment of an asset or extinguishment of any right there in amounts to a transfer of a capital asset. While, it is no doubt true that the appellant continues to remain a shareholder of the company even

BELLANDUR CHIKKAGURAPPA JAYARAMREDDY,BENGALURU vs. THE ASST. COMMISSIONER OF INCOME-TAX CIRCLE 4(3)(1), BENGALURU

The appeal of the assessee is allowed

ITA 1322/BANG/2019[2014-15]Status: DisposedITAT Bangalore05 Jan 2022AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year : 2014-15

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 2(47)(v)Section 234BSection 50C

2(47)(v) of the I.T .Act. Further, the first proviso to Sec.50C(1) of the Act would support the case of the assessee. Though the proviso was inserted by the Finance Act, 2016 with effect from 1.4.2017, it is only clarificatory in nature. 34. Assuming for argument sake though not conceding, if the date of transfer is considered

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 270/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2018AY 2011-12

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 266/BANG/2017[2009-10]Status: DisposedITAT Bangalore25 May 2018AY 2009-10

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 264/BANG/2017[2008-09]Status: DisposedITAT Bangalore25 May 2018AY 2008-09

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 265/BANG/2017[2008-09]Status: DisposedITAT Bangalore25 May 2018AY 2008-09

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 268/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2018AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 267/BANG/2017[2009-10]Status: DisposedITAT Bangalore25 May 2018AY 2009-10

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 271/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2018AY 2011-12

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

ITA 269/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2018AY 2010-11

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Vishnu Moorthi, CAFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 194CSection 201Section 201(1)

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v

M/S. S P R DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, all the appeals filed by the assessee are allowed

ITA 297/BANG/2020[2008-09]Status: DisposedITAT Bangalore09 Feb 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri L Bharath, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 153A

price of the property and sale takes place only after completion of the project and assessee’s share of sale consideration is identified. The proposed sale agreement cannot be put into action due to various litigations pending with various levels. Nobody can transfer the title of the property when assessee itself is owing the landed property. Being so, no project

M/S. S P R DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, all the appeals filed by the assessee are allowed

ITA 295/BANG/2020[2006-07]Status: DisposedITAT Bangalore09 Feb 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri L Bharath, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 153A

price of the property and sale takes place only after completion of the project and assessee’s share of sale consideration is identified. The proposed sale agreement cannot be put into action due to various litigations pending with various levels. Nobody can transfer the title of the property when assessee itself is owing the landed property. Being so, no project

M/S. S P R DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(3), BANGALORE

In the result, all the appeals filed by the assessee are allowed

ITA 296/BANG/2020[2007-08]Status: DisposedITAT Bangalore09 Feb 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri L Bharath, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 153A

price of the property and sale takes place only after completion of the project and assessee’s share of sale consideration is identified. The proposed sale agreement cannot be put into action due to various litigations pending with various levels. Nobody can transfer the title of the property when assessee itself is owing the landed property. Being so, no project

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

ITA 84/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

ITA 63/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country