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21 results for “transfer pricing”+ Section 246A(1)(b)clear

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Key Topics

Section 14337Disallowance14Deduction13Section 15412Section 143(3)11Depreciation11Section 153A9Section 2639Addition to Income6

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

ITA 1054/BANG/2024[2020-21]Status: DisposedITAT Bangalore27 Sept 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 250Section 270ASection 270A(7)Section 270A(8)Section 40Section 43

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

Showing 1–20 of 21 · Page 1 of 2

Section 10B5
Section 1154
Section 115Q4
ITA 303/BANG/2022[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18
For Appellant: \nShri Chaitanya, Sr. Advocate a/wFor Respondent: \nMs. Neera Malhotra, CIT-DR
Section 143(2)Section 143(3)Section 92C

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production

M/S. GE BE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(2), BANGALORE

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

ITA 2615/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 May 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George K. George

For Appellant: Shri Sachit Jolly &For Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)Section 92D

transfer pricing matters 20. The learned AO and the learned Panel has erred in not allowing an amount of INR 3,34,92,043 under section 40(a)(ia) of the Act towards the disallowance of year end provisions pertaining to AY 14-15 for non-deduction of taxes, without appreciating the fact that the provisions were-reversed during

M/S MANN & HUMMEL FILTER PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, appeal of the Assessee is treated as allowed for statistical purposes

ITA 793/BANG/2019[2013-14]Status: DisposedITAT Bangalore29 Jun 2020AY 2013-14

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

For Appellant: Ms. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Priyadarshi Misra, Jt.CIT(DR)(ITAT), Bengaluru
Section 92(1)Section 92ASection 92B(1)Section 92C

B R BASKARAN, ACCOUNTANT MEMBER IT(TP)A No.793/Bang/2019 Assessment year: 2013-14 M/s. Mann and Hummel Filter Vs. The Deputy Commissioner of Private Limited,2nd Floor, “Prasad Income Tax, Enclave”, 118, 119, Industrial Circle 4(2)(1), Suburb,2nd Stage, 5th Main, Bangalore. Yeshwanthpura, Bangalore – 560 022. PAN: AAECM 4056D APPELLANT RESPONDENT Appellant by : Ms. Tanmayee Rajkumar, Advocate Respondent

DINESH KUMAR SINGHI,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2011-12 is partly allowed

ITA 699/BANG/2015[2005-06]Status: DisposedITAT Bangalore10 Apr 2018AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V. Arvind, Standing Counsel for Dept
Section 10BSection 132Section 143(3)Section 148Section 153ASection 154

1 before the jurisdictional Central Excise authorities providing full description of the goods being exported from the unit and invoice would bear the description that “THE SHIPMENT IS UNDER EOU”. The above requirement has been fulfilled ARE-1 forms were submitted. This is evident from seized material marked as A2/BMM/3. The above aspect also has been confirmed by accountant

HEWLETT PACKARD GLOBALSOFT PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, the appeal filed by the assessee is

ITA 162/BANG/2012[2005-06]Status: DisposedITAT Bangalore24 Jun 2016AY 2005-06

Bench: Shri A. K. Garodia & Shri Vijay Pal Rao

For Appellant: Shri T.Suryanarayana, AdvocateFor Respondent: Mrs Neera Malhotra, CIT-II
Section 143(3)Section 144CSection 250Section 263

1. Assessment order bad in law as due process of law not followed No fresh assessment framed 1.1 The Assistant Commissioner of Income-tax, Circle-11 (4) ("AO") erred in not framing a fresh assessment under section 143(3) of the Act in accordance with the directions contained in the order under section 263 of the Act, passed

BMM ISPAT LIMITED,HOSPET vs. DCIT, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 779/BANG/2015[2008-09]Status: DisposedITAT Bangalore10 Apr 2018AY 2008-09

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Pradeep, C.AFor Respondent: Shri K.V.Arvind, Standing Counsel for Dept
Section 132Section 143(3)Section 153ASection 153DSection 234BSection 234DSection 68

246A of the Income Tax Act, 1961, the Commissioner of Income Tax (Appeals) has no jurisdiction to examine the validity of the search operations carried out under Section 132 of the said Act. Learned Senior Counsel appearing for the petitioners has further submitted that the foundation of the assessment made hereunder in the search operations carried out against the petitioners

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S TEXAS INSTRUMENTS (INDIA) PVT LTD , BANGALORE

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

ITA 525/BANG/2019[2011-12]Status: FixedITAT Bangalore11 Mar 2022AY 2011-12

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115Section 115QSection 143(3)Section 246A

b) any order of assessment under sub-section (3) of section 143. Thus the grievance of the assessee on DDT liability falls under different class of liabilities mentioned in sec. 246A of the Act. Further, Sec. 246A provides for appellate remedy for different types of tax demands raised upon the assessee and there should not be any dispute that

M/S TEXAS INSTRUMENTS (INDIA) PVT LTD ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

ITA 275/BANG/2019[2011-12]Status: FixedITAT Bangalore11 Mar 2022AY 2011-12

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115Section 115QSection 143(3)Section 246A

b) any order of assessment under sub-section (3) of section 143. Thus the grievance of the assessee on DDT liability falls under different class of liabilities mentioned in sec. 246A of the Act. Further, Sec. 246A provides for appellate remedy for different types of tax demands raised upon the assessee and there should not be any dispute that

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 248/BANG/2018[2003-04]Status: DisposedITAT Bangalore20 Sept 2019AY 2003-04

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 243/BANG/2018[1999-00]Status: DisposedITAT Bangalore20 Sept 2019AY 1999-00

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 249/BANG/2018[2004-05]Status: DisposedITAT Bangalore20 Sept 2019AY 2004-05

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 253/BANG/2018[2008-09]Status: DisposedITAT Bangalore20 Sept 2019AY 2008-09

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 250/BANG/2018[2005-06]Status: DisposedITAT Bangalore20 Sept 2019AY 2005-06

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 251/BANG/2018[2006-07]Status: DisposedITAT Bangalore20 Sept 2019AY 2006-07

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 247/BANG/2018[2001-02]Status: DisposedITAT Bangalore20 Sept 2019AY 2001-02

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 254/BANG/2018[2011-12]Status: DisposedITAT Bangalore20 Sept 2019AY 2011-12

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , UDUPI , UDUPI

240 & 241/Bang/2018

ITA 255/BANG/2018[2012-13]Status: DisposedITAT Bangalore20 Sept 2019AY 2012-13

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 252/BANG/2018[2007-08]Status: DisposedITAT Bangalore20 Sept 2019AY 2007-08

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

ITA 245/BANG/2018[2000-01]Status: DisposedITAT Bangalore20 Sept 2019AY 2000-01

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

For Appellant: Shri Anil Kumar Rao, C. AFor Respondent: Shri Vikas Suryavamshi, Addl. CIT DR
Section 143Section 154

246A(1)(a). 3. This non-credit of TDS was dealt with by the ITAT in respect of claim for credit of such TDS in its orders in ITA No 346/Bang/2008 and 347/Bang/2008 for Asst year 1999-2000 and 2000-01 and the Tribunal directed the granting of the same after verification. Said common order is enclosed ( Annexure