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73 results for “transfer pricing”+ Section 69Cclear

Sorted by relevance

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Key Topics

Addition to Income62Section 13259Section 153A54Section 6849Section 69C34Section 143(3)34Section 14833Section 14733Section 132(4)22Reassessment

M/S. MUKKA PROTENIS LIMITED,MANGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BANGALORE

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

ITA 433/BANG/2022[2018-19]Status: DisposedITAT Bangalore17 Nov 2022AY 2018-19
For Appellant: Shri V. Srinivasan, Advocate
Section 115BSection 143Section 153DSection 263Section 69C

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA. Page 13 (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

DELL INDIA PRIVATE LTD.,,BANGALORE vs. JCIT, BANGALORE

Showing 1–20 of 73 · Page 1 of 4

16
Reopening of Assessment16
Natural Justice13

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

ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11

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

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92C

transferred to the customer upon delivery of goods. In the case of Goods-in-Transit as on 31st March, the invoices are raised and the VAT liability is discharged, however, as the proof of delivery of the goods to the customers is not received, the same is reversed and subsequently recognized as sales during the next financial year, once

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

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

ITA 831/BANG/2017[2009-10]Status: DisposedITAT Bangalore29 Jun 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri. Percy Pardiwala, Sr. CounselFor Respondent: Shri. Sanjay Kumar S. K, CIT(DR)(ITAT), Bengaluru
Section 142(1)Section 143(2)Section 143(3)Section 40Section 80JSection 92C

Pricing Officer ("TPO") where the same has been considered as part of operating expenditure.” During the year the assessee claimed a sum of Rs.2,18,82,313 under the head ‘repairs & maintenance – Building and Plant & Machinery’. After calling for various details from the assessee, the AO analysed the break-up of expenditure and arrived at a disallowance of Rs.92

TEXAS INSTRUMENTS (INDIA) PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

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

ITA 852/BANG/2017[2009-10]Status: DisposedITAT Bangalore29 Jun 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri. Percy Pardiwala, Sr. CounselFor Respondent: Shri. Sanjay Kumar S. K, CIT(DR)(ITAT), Bengaluru
Section 142(1)Section 143(2)Section 143(3)Section 40Section 80JSection 92C

Pricing Officer ("TPO") where the same has been considered as part of operating expenditure.” During the year the assessee claimed a sum of Rs.2,18,82,313 under the head ‘repairs & maintenance – Building and Plant & Machinery’. After calling for various details from the assessee, the AO analysed the break-up of expenditure and arrived at a disallowance of Rs.92

NAVUNDA ABDULLA BADRUDDIN,UDUPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BANGALORE

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

ITA 508/BANG/2022[2018-19]Status: DisposedITAT Bangalore20 Sept 2022AY 2018-19

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.Shri Navunda Abdulla Badruddin Vs Pcit, Central O Thuwfeeq Manzil C.R. Building, Queen'S Road Maski Navunda, Kundapur Bengaluru 560001 Udupi 576224 Pan – Aevpa6893G (Appellant) (Respondent) Assessee By: Shri V. Narendra Sharma, Advocate Revenue By: Shri Manjunath Karkihalli, Cit-Dr Date Of Hearing: 14/09/2022 Date Of Pronouncement: 20/09/2022 O R D E R Per: Padmavathy, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax(Pcit) U/S.263 Of The Income Tax Act 1961 (The Act), Bangalore In Appeal No. 263/Pr.Cit(C)/2001-02 Dated 28.03.2022 For Ay 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Order Of Revision Passed By The Learned Principal Commissioner Of Income Tax [Central], Bengaluru, Under Section 263 Of The Act Dated 28/03/2022, In So Far As It Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case. 2. The Learned Principal Commissioner Of Income Tax Is Not Justified In Law & On Facts To Set Aside The Assessment Order Passed Under Section 143[3] R.W.S. 153D Of The Act Dated 19/12/2019 & Direct

For Appellant: Shri V. Narendra Sharma, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 115BSection 143Section 153DSection 263Section 69C

69C of the Act and should have been taxed under Section 115BBE of the Act and since the AO is did not enquire or verify the said expenditure the order of the AO is erroneous and prejudicial to the interest of Revenue to that extent. 7. Before us the learned A.R. reiterated the submissions made before the lower authorities

BANGALORE BEVERAGES LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX (OSD) WARD-1(1)(3), BANGALORE

In the result, the appeal filed by the assessee in ITA

ITA 294/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri K.R. Pradeep, A.R. &For Respondent: Ms. Neera Malhotra, D.R

price or all significant risks and rewards of ownership have been transferred to the buyer and the seller retains no effective control of the goods transferred to a degree usually associated with ownership; and (ii) no significant uncertainty exists regarding the amount of the consideration that will be derived from the sale of the goods. 12. 12. In a transaction

M/S BANGALORE BEVERAGES PVT LIMITED ,BANGALORE vs. THE INCOME TAX OFFICER ARD-1(1)(1), BANGALORE

In the result, the appeal filed by the assessee in ITA

ITA 438/BANG/2018[2013-14]Status: DisposedITAT Bangalore25 May 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri K.R. Pradeep, A.R. &For Respondent: Ms. Neera Malhotra, D.R

price or all significant risks and rewards of ownership have been transferred to the buyer and the seller retains no effective control of the goods transferred to a degree usually associated with ownership; and (ii) no significant uncertainty exists regarding the amount of the consideration that will be derived from the sale of the goods. 12. 12. In a transaction

M/S. JANATHA FISH MEAL & OIL PRODUCTS,UDUPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL), , BENGALURU

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

ITA 489/BANG/2022[2018-19]Status: DisposedITAT Bangalore20 Sept 2022AY 2018-19

Bench: Shri N.V. Vasudevan & Ms.Padmavathy S.M/S. Janatha Fish Meal & Vs Pcit, Central Oil Products C.R. Building D.No. 1-4(9), Manur Fisheries Queen'S Road Road, Kota, Post Kota Bengaluru 560001 Udupi 0576221 Pan – Aaefj1257G (Appellant) (Respondent) Assessee By: Shri V. Narendra Sharma, Advocte Revenue By: Shri Manjunath Karkihalli, Cit-Dr Date Of Hearing: 14/09/2022 Date Of Pronouncement: 20/09/2022 O R D E R Per: Padmavathy, A.M. This Appeal Is Against The Revision Order Passed Under Section 263 Of The Income Tax Act, 1961 (The Act) Dated 28.03.2022 Passed For Ay 2018-19 By The Principal Commissioner Of Income Tax, (Pcit) Bangalore.

For Appellant: Shri V. Narendra Sharma, AdvocteFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 115BSection 143Section 153DSection 263Section 269Section 269SSection 69C

69C in the books of account and whether the same is required to be taxed u/s 115BBE of Income Tax Act. Further cash investment amounting to Rs.4.5 crore made during the period under consideration needs to be verified as to whether the said transaction arc in violation of section 269ST of the Act. The claims of the assessee made during

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

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

ITA 2374/BANG/2018[2013-14]Status: DisposedITAT Bangalore08 Apr 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &
Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

transfer of shares in M/s. Parag Shilpa Investment Ltd (PS IT Infrastructure & Services Ltd) of Rs. 20,25,08,735/-. 21. That the authorities below erred in making addition of Rs.60,75,262/- u/s 69C of the Act. 22. That the authorities below erred in charging 3% of capital gains as the commission paid u/s 69C

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

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

ITA 2373/BANG/2018[2012-13]Status: DisposedITAT Bangalore08 Apr 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &
Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

transfer of shares in M/s. Parag Shilpa Investment Ltd (PS IT Infrastructure & Services Ltd) of Rs. 20,25,08,735/-. 21. That the authorities below erred in making addition of Rs.60,75,262/- u/s 69C of the Act. 22. That the authorities below erred in charging 3% of capital gains as the commission paid u/s 69C

LAXMIPAT DUDHERIA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

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

ITA 2376/BANG/2018[2015-16]Status: DisposedITAT Bangalore08 Apr 2019AY 2015-16

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &
Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

transfer of shares in M/s. Parag Shilpa Investment Ltd (PS IT Infrastructure & Services Ltd) of Rs. 20,25,08,735/-. 21. That the authorities below erred in making addition of Rs.60,75,262/- u/s 69C of the Act. 22. That the authorities below erred in charging 3% of capital gains as the commission paid u/s 69C

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

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

ITA 2375/BANG/2018[2014-15]Status: DisposedITAT Bangalore08 Apr 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &
Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

transfer of shares in M/s. Parag Shilpa Investment Ltd (PS IT Infrastructure & Services Ltd) of Rs. 20,25,08,735/-. 21. That the authorities below erred in making addition of Rs.60,75,262/- u/s 69C of the Act. 22. That the authorities below erred in charging 3% of capital gains as the commission paid u/s 69C

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1451/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1445/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2130/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2129/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1448/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1447/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1457/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1456/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books