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7 results for “transfer pricing”+ Section 56(2)(viib)clear

Sorted by relevance

Chandigarh50Mumbai35Delhi32Chennai10Hyderabad9Bangalore7Kolkata7Pune6Nagpur5Jaipur5Visakhapatnam2Jodhpur2Ahmedabad2Raipur1

Key Topics

Section 56(2)(viib)7Addition to Income7Section 92C5Disallowance5Section 143(3)4Section 14A4Section 143(2)3Transfer Pricing3Section 92A(2)2

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

ITA 1185/BANG/2025[2018-19]Status: DisposedITAT Bangalore11 Aug 2025AY 2018-19
For Appellant: Shri. Ramesh Babu, CAFor Respondent: Shri. Swaroop Manava, Addl. CIT(DR)(ITAT), Bangalore
Section 14ASection 56(2)Section 56(2)(viib)

56(2)(viib) of the I. T\nAct, 1961 read with Rule IIV and IIVA and the rejection of\nthe same was made by the learned Assessing officer for the\nflimsy, immaterial and irrelevant reasons that the CA's\nreport is qualified and not supported by ant material\nthough the comments in the report are common and general\nin nature

RAAJRATNA ENERGY HOLDINGS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

Accordingly, this\nground is allowed for statistical purposes

Section 682
Section 56(2)2
Capital Gains2
ITA 1184/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Aug 2025AY 2017-18
Section 14ASection 56(2)Section 56(2)(viib)

56(2)(viib) of the I. T\nAct, 1961 read with Rule IIV and IIVA and the rejection of\nthe same was made by the learned Assessing officer for the\nflimsy, immaterial and irrelevant reasons that the CA's\nreport is qualified and not supported by ant material\nthough the comments in the report are common and general\nin nature

M/S. MOBICOM TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. INCOME-TAX OFFICER, WARD-4(1)(4) , BANGALORE

In the result, the appeal filed by the assessee stands dismissed

ITA 494/BANG/2023[2016-17]Status: DisposedITAT Bangalore12 Sept 2023AY 2016-17

Bench: Shri Chandra Poojari & Ms. Madhumita Royassessment Year : 2016-17

For Appellant: Shri Padam Chand KhinchaFor Respondent: Shri V. Parithivel, JCIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 56Section 56(2)(viib)

viib) of sub-section (2) of section 56 shall be the value, on the valuation date, of such unquoted equity shares as determined in the following manner under clause (a) or clause (b), at the option of the assessee, namely: - the fair market value of unquoted equity Page 4 1. Shares = (A-L) x (PV) (PE) where, A = book value

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

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

ITA 310/BANG/2023[2018-19]Status: DisposedITAT Bangalore25 Jul 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Years : 2018-19

For Appellant: Shri KR Pradeep & Ms. Girija G.P, AdvocatesFor Respondent: Shri Vilas Shinde, CIT (DR)
Section 56(2)(viib)

section 56(2)(viib) read with income tax rule 11UA of Income Tax Rule. The AO cannot interfere in the method selected for the valuation of the shares. However, the AO can scrutinize the contents or working of the method adopted by the assessee so as to find out the fair valuation. In case, the AO is not satisfied with

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

ITA 261/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri Narendra Kumar Jain, Advocate
Section 143(3)Section 68Section 92C

section 56(2)(viib) does not apply on shares of the non-resident. Accordingly, we allow ground no. 3 and direct the Ld. Assessing Officer to delete the addition u/s. 56(2)(viib) of the Act of Rs. 198 crores. 30. Ground no. 4 is the adhoc disallowance made by the Ld. Assessing Officer on cost of vehicles, repairs expenditure

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

ITA 2929/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2023AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Smt. Manasa Ananthan, AdvocateFor Respondent: Ms. Neera Malthora, CIT-DR
Section 143(2)Section 143(3)Section 92A(2)Section 92C

transfer of control. Therefore, the price determined by the TPO is upheld for the above reasons and the grounds No. 5 to 10 raised by the Assessee are accordingly dismissed. M/s. Palmer Investment Group Ltd. 26. Ground Nos. 11 to 14 deal with aspect of the method and computation mechanism adopted by the learned TPO. As mentioned above

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

ITA 2930/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2023AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Smt. Manasa Ananthan, AdvocateFor Respondent: Ms. Neera Malthora, CIT-DR
Section 143(2)Section 143(3)Section 92A(2)Section 92C

transfer of control. Therefore, the price determined by the TPO is upheld for the above reasons and the grounds No. 5 to 10 raised by the Assessee are accordingly dismissed. M/s. Palmer Investment Group Ltd. 26. Ground Nos. 11 to 14 deal with aspect of the method and computation mechanism adopted by the learned TPO. As mentioned above