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10 results for “transfer pricing”+ Section 32(1)(iia)clear

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Key Topics

Section 3521Section 15415Addition to Income7Section 80J6Deduction6Section 80I5Disallowance5Section 92B4Section 143(3)3

M/S MAXIM INDIA INTERGRATED CIRCUIT DESIGN PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

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

ITA 1573/BANG/2017[2013-14]Status: DisposedITAT Bangalore02 Nov 2020AY 2013-14

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

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Gollapinni Mallikarjuna, D.R
Section 143(3)Section 234CSection 40

section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely ;— (a) to (b)** ** ** (e) transactional net margin method, by which,— (i) the net profit margin realised by the enterprise from an international transaction

Comparables/TP3
TP Method3
Transfer Pricing3

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

transfer pricing issues having 11 pages, various case laws along with its compilation and contended that the number of employees employed in the year in dispute is far exceeding 10% of the employees as on the last day of the previous year. The ld. AR in support of his contention filed the auditors certificate place on pages

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

transfer pricing issues having 11 pages, various case laws along with its compilation and contended that the number of employees employed in the year in dispute is far exceeding 10% of the employees as on the last day of the previous year. The ld. AR in support of his contention filed the auditors certificate place on pages

M/S TE CONNECTIVITY INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU,CIRCLE-1, , BENGALURU

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

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 40Section 92

transfer pricing adjustment should be restricted only to the international transactions with the AE. This ground is allowed in favour of the assessee. Corporate tax issues 53. The assessee has raised ground Nos.11 to 18 regarding depreciation and additional depreciation as follows:- “11. That on the facts and circumstances of the case, the learned AO/ learned Dispute Resolution Panel (learned

DCIT, BANGALORE vs. M/S SOBHA DEVELOPERS LTD.,, BANGALORE

In the result, appeal of the revenue is partly allowed

ITA 1410/BANG/2013[2008-09]Status: DisposedITAT Bangalore09 Jan 2015AY 2008-09

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

For Appellant: Shri C.H. Sundar Rao, CIT-I (DR)For Respondent: Shri V. Srinivasan, C.A
Section 80I

price. Once the deal was struck, the builder or the owner, as the case may be, make a bifurcation of sale proceeds towards the sale of undivided interest in land and that of the sale of the built up area. This bifurcation could be resorted to mainly for the registration of the undivided interest in land in favour

MICRO LABS LTD.,,BANGALORE vs. ACIT, BANGALORE

In the result, the appeals viz

ITA 1429/BANG/2013[2009-10]Status: DisposedITAT Bangalore05 Mar 2015AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2009-10

For Appellant: Shri S. Parthasarthi, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 154Section 35

price. So the knowhow given to them is only for limited purpose of registering with the drug control authorities for approval for human consumption. The foreign entities who get the dossiers will get rights to ITA Nos.1412 & 1429/B/13 & 764/B/14 Page 11 of 29 market the assessee’s products in their territory and the actual manufacture in course of time will

MICROLABS LIMITED,BANGALORE vs. ADDL. CI.T., BANGALORE

In the result, the appeals viz

ITA 764/BANG/2014[2009-10]Status: DisposedITAT Bangalore05 Mar 2015AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2009-10

For Appellant: Shri S. Parthasarthi, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 154Section 35

price. So the knowhow given to them is only for limited purpose of registering with the drug control authorities for approval for human consumption. The foreign entities who get the dossiers will get rights to ITA Nos.1412 & 1429/B/13 & 764/B/14 Page 11 of 29 market the assessee’s products in their territory and the actual manufacture in course of time will

DCIT, BANGALORE vs. M/S MICRO LABS LTD.,, BANGALORE

In the result, the appeals viz

ITA 1412/BANG/2013[2009-10]Status: DisposedITAT Bangalore05 Mar 2015AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2009-10

For Appellant: Shri S. Parthasarthi, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 154Section 35

price. So the knowhow given to them is only for limited purpose of registering with the drug control authorities for approval for human consumption. The foreign entities who get the dossiers will get rights to ITA Nos.1412 & 1429/B/13 & 764/B/14 Page 11 of 29 market the assessee’s products in their territory and the actual manufacture in course of time will

MEDREICH LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

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

ITA 451/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 451/Bang/2022 Assessment Year : 2017-18 M/S. Medreich Ltd., No. 12/8, Medreich The Assistant House, Commissioner Of Saraswati Ammal Income Tax, Street, Central Circle – Maruti Seva Nagar, 1(2), Vs. Bangalore – 560 033. Bangalore. Pan: Aabcm1458Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Ld.Acit, Central Circle – 1(2), Bangalore Dated 26/04/2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “General Ground 1.1 The Learned Assistant Commissioner Of Income Tax, Central Circle-1(2), Bangalore (`A0') Erred In Passing The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (`The Act) In The Manner Passed

For Respondent: Shri Padam Chand
Section 143(3)Section 14ASection 92B

32,280/- by applying interest rate of 5.875% i.e. LIBOR + 450 basis points. 7. The Ld.AR placed reliance on decision of Hon’ble Delhi Tribunal in Kusum Healthcare Pvt.Ltd vs. ACIT reported in (2015) 62 Taxmann.com 79, deleted addition by considering the above principle, and subsequently Hon'ble Delhi High Court in Pr. CIT vs. Kusum Health Care

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,RAMANAGARAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-2, BANGALORE

In the result, the appeal of the assessee is allowed

ITA 362/BANG/2021[2016-17]Status: DisposedITAT Bangalore18 Jul 2022AY 2016-17

Bench: Shri N.V Vasudevan, Hon’Ble & Shri Laxmi Prasad Sahu

For Appellant: Ms. Hirali Desai, ARFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 92D

1. That on facts and circumstances of the case and in law, the order passed by the Learned AO, pursuant to the directions of the Hon'ble Dispute Resolution Panel - 2, Bangalore ('Panel' or 'DRP'), and the order of the Learned Deputy Commissioner of Income-tax, Transfer Pricing- Circle (2)(2)(2), Bengaluru ('Learned TPO') to the extent prejudicial