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7 results for “transfer pricing”+ Section 32Aclear

Sorted by relevance

Mumbai28Delhi18Indore8Bangalore7Hyderabad6Chennai5Kolkata5Visakhapatnam3Ahmedabad3SC2Telangana2Cuttack1Cochin1Jaipur1

Key Topics

Section 36(1)(viia)8Section 80J6Deduction6Addition to Income6Section 143(3)4Section 10A4Transfer Pricing4Comparables/TP4Disallowance

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

transfer pricing exercise would therefore fail. Therefore in keeping with the OECD guidelines, endeavor should be made to bring in comparable companies for the purpose of broad comparison. Therefore the working capital adjustment as claimed by the Assessee should be allowed. We hold and direct accordingly.” 20. We notice that the Delhi bench of Tribunal has held in the case

M/S. TEXTRON INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

4
Section 133(6)3
Section 92C(2)3
Section 1152

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

ITA 1228/BANG/2010[2006-07]Status: DisposedITAT Bangalore13 Jan 2016AY 2006-07

Bench: Shri Vijaypal Rao & Shri Inturi Rama Raoi.T. (T.P) A. No.1228/Bang/2010 (Assessment Year : 2006-07) M/S. Textron India Private Limited, (Formerly Known As Textron Global Technology Centre Pvt. Ltd.) Global Village, Rvce Post, Mylasandra, Off Mysore Road, Bangalore-560 059 …. Appellant. Pan Aacct 0118M Vs. Dy. Commissioner Of Income Tax, Circle 12(4), Bangalore. ….. Respondent. Appellant By : Shri P.K. Prasad. Respondent By : Smt. Neera Malhotra, Cit (D.R) Date Of Hearing : 30.11.2015. Date Of Pronouncement : 13.1.2016. O R D E R Per Shri Vijaypal Rao, J.M. :

For Appellant: Shri P.K. PrasadFor Respondent: Smt. Neera Malhotra, CIT (D.R)
Section 133(6)Section 143(3)Section 92C(2)

Transfer Pricing provisions, however, in due course of discussion and adjudication of this issue in a series of decisions of this Tribunal, commonly accepted tolerance range of 5% to 25% of the total revenue from RPT has been considered as reasonable depending upon the facts and circumstances of each case. In the case on hand, the availability of the comparables

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

TELELOGIC INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 1599/BANG/2012[2008-09]Status: DisposedITAT Bangalore09 Mar 2016AY 2008-09

Bench: Shri Abraham P George & Shri Vijay Pal Rao

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Smt. Neera Malhotra, Addl. CIT (D.R)
Section 10ASection 133(6)Section 143(3)Section 144C(5)Section 92C(2)

Transfer Pricing Officer (‘TPO’) by considering the various comparable companies and confirmed by the DRP. The assessee company was incorporated on 14.11.2000. The assessee is engaged in the business of selling licenses for use of software product developed by its parent and group companies. It also provides product development, after sales services, consultancy services and training services. The assessee basically

SOFTBRANDS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 1094/BANG/2011[2007-08]Status: DisposedITAT Bangalore26 Aug 2016AY 2007-08

Bench: Shri Abraham P George & Shri Vijay Pal Rao

For Appellant: Shri Cherian K Baby, C. AFor Respondent: Shri Sibichen K Mathew, CIT (D.R)
Section 10ASection 133(6)Section 143(3)

transfer prices actually charged by your appellant to its customer is to be held as at arm’s length and the addition proposed by the TPO and acted upon by the Assessing Officer based on approval of the DRP in the Assessment Order is to be ordered to be deleted. 6 IT(TP)A No.1094/Bang/2011 Ground III For these

ACIT, MANGALORE vs. M/S CORPORATION BANK, MANGALORE

In the result, appeal of the revenue stands dismissed

ITA 1264/BANG/2013[2011-12]Status: DisposedITAT Bangalore11 Mar 2015AY 2011-12

Bench: Shri Rajpal Yadav & Shri Abraham P George

For Appellant: Shri S. Ananthan, CAFor Respondent: Dr. P.K.Srihari, Addl.CIT
Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viiia)

Transfer of Undertakings) Act, 1980, or any other bank being a bank included in the Second Schedule to the Reserve Bank of India Act, 1934; (iii) "public financial institution" shall have the meaning assigned to it in section 4A of the Companies Act, 1956 (1 of 1956); (iv) "State financial corporation" means a financial corporation established under section