BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

45 results for “transfer pricing”+ Section 928clear

Sorted by relevance

Mumbai156Delhi115Bangalore45Ahmedabad36Kolkata24Hyderabad22Pune20Chennai12Jaipur10Cuttack9Chandigarh8Visakhapatnam4Karnataka3Cochin2Surat2Ranchi1SC1Orissa1Telangana1Indore1

Key Topics

Addition to Income30Section 14A27Section 10A25Section 143(3)24Transfer Pricing23Comparables/TP22Section 32(1)(ii)20Section 3717Disallowance

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

In the result, appeal of the assessee is partly allowed

ITA 202/BANG/2021[2015-16]Status: DisposedITAT Bangalore26 Jul 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.202/Bang/2021 Assessment Year :2015-16 M/S. Nike India Pvt.Ltd., Vs. Dcit, Ground & First Floor, Circle – 3(1)(1), Olympia Building, No.66/1, Bagmane Tech Bengaluru. Park, C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aabcn 9612 K Appellant Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Smt. Susan Dolores George, Cit(Osd)(Itat), Bengaluru. Date Of Hearing : 21.07.2022 Date Of Pronouncement : 26.07.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(ITAT), Bengaluru
Section 144(3)Section 92C

transfer pricing adjustment of Rs.22.24 crores. The Ld DRP also confirmed the same. 19.3 The Ld A.R submitted that the assessee has furnished various evidences to prove that the sourcing agent has provided services to the assessee. He submitted that the assessee has utilized services of one USA entity and one Singapore entity. However, the assessee has paid commission only

Showing 1–20 of 45 · Page 1 of 3

14
Section 92C12
Deduction11
Section 133(6)10

CORP ATTIRE,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(3)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 202/BANG/2022[2019-20]Status: DisposedITAT Bangalore31 May 2022AY 2019-20

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.202/Bang/2021 Assessment Year :2015-16 M/S. Nike India Pvt.Ltd., Vs. Dcit, Ground & First Floor, Circle – 3(1)(1), Olympia Building, No.66/1, Bagmane Tech Bengaluru. Park, C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aabcn 9612 K Appellant Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Smt. Susan Dolores George, Cit(Osd)(Itat), Bengaluru. Date Of Hearing : 21.07.2022 Date Of Pronouncement : 26.07.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(ITAT), Bengaluru
Section 144(3)Section 92C

transfer pricing adjustment of Rs.22.24 crores. The Ld DRP also confirmed the same. 19.3 The Ld A.R submitted that the assessee has furnished various evidences to prove that the sourcing agent has provided services to the assessee. He submitted that the assessee has utilized services of one USA entity and one Singapore entity. However, the assessee has paid commission only

CONCUR TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1), BANGALORE

Appeal of the assessee is partly allowed as indicated above

ITA 2550/BANG/2024[2021-22]Status: DisposedITAT Bangalore11 Nov 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru
Section 144Section 144BSection 144C

transfer pricing ("TP matter) 3. The learned TPO/ AO erred, in law and in facts, by rejecting comparable companies forming part of the TP study report as well as certain additional comparable companies as they do not appear in TPO's search matrix. 4. The learned TPO/ AO erred in law and in facts by not accepting the economic analysis

KSHEMA TECHNOLOGIES (SINCE MERGED WITH MPHASIS LTD),BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal is allowed for statistical

ITA 1105/BANG/2012[2005-06]Status: DisposedITAT Bangalore22 Apr 2016AY 2005-06

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Mrs. Neera Malhotra, CIT-II (D.R)
Section 92CSection 92C(3)

Transfer Pricing Officer and Commissioner of Income Tax (Appeals) - IV have erred in not allowing the benefit of the +/-5% range mentioned in the proviso to section 92C(2). 13. REDUCTION IN DEDUCTION UNDER SECTION l0A OF THE ACT IN RESPECT OF EXPENDITURE INCURRED IN FOREIGN CURRENCY On the facts and in the circumstances of the case, the learned

M/S ESSILOR INDIA P LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the both the appeals are treated as partly allowed

ITA 227/BANG/2015[2010-11]Status: DisposedITAT Bangalore05 Feb 2016AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raoit(Tp)A No.29/Bang/2014 (Assessment Year: 2009-10) & It(Tp)A No.227/Bang/2015 (Assessment Year: 2010-11) M/S.Essilor India Pvt.Ltd. No.71/1, Brigade Plaza, 6Th Floor, S C Road, Gandhinagar, Bangalore-9. … Appellant Pan:Aaace 4623 J Vs. Deputy Commissioner Of Income-Tax, Circle 11(3), Bangalore. … Respondent

For Appellant: Shri S.Ramasubramanyam, CAFor Respondent: Smt. Neera Malhotra, CIT(DR)
Section 143(3)Section 14ASection 234C

928 advertisement expenses of Rs.8,86,67,743/-) Profit 19,23,40,672 OP/OC 20.22% Additional advertisement expenses 8,86,67,743 incurred for promotion of brand on behalf of the AE Arm’s Length Price NIL Reimbursement received for advertisement expenses incurred for brand promotion of AE’s products ITA No.29/B/14 & 227/B/15 Page 7 of 28 (i) Adjustment

M/S. PAREXEL INTERNATIONAL CLINICAL RESEARCH PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(2), BENGALURU

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

ITA 2634/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Oct 2021AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Danesh Bafna, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92BSection 92C(1)

Transfer Pricing adjustment cannot be on vague generalities. Accordingly, the adjustment made on account of location saving' for sums amounting to Rs.54,69,43,636/- is directed to be deleted. 20. In view of our finding, the other pleas and arguments raised by the parties before us regarding powers of the TPO at the time of reference and recording

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

transferred to new SEZ units were less than 20% of the total number of the employees, and therefore the condition stipulated in Circular 12 & 14 of 2014 dated 18/07/2014. This criteria has not been considered by the Ld.AO. 6.15. We have referred to the observations by the Ld.CIT(A) for assessment years 2007-08 to 2009-10 wherein there

M/S. TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

ITA 1339/BANG/2010[2006-07]Status: DisposedITAT Bangalore10 May 2019AY 2006-07

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Aliasger Rampurawala, CAFor Respondent: Shri B.K. Panda, CIT (DR)
Section 133(6)Section 143(3)

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

TIMKEN ENGINEERING & RESEARCH INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

ITA 604/BANG/2012[2007-08]Status: DisposedITAT Bangalore10 May 2019AY 2007-08

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Aliasger Rampurawala, CAFor Respondent: Shri B.K. Panda, CIT (DR)
Section 133(6)Section 143(3)

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

DCIT, BANGALORE vs. M/S TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

ITA 686/BANG/2012[2007-08]Status: DisposedITAT Bangalore10 May 2019AY 2007-08

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Aliasger Rampurawala, CAFor Respondent: Shri B.K. Panda, CIT (DR)
Section 133(6)Section 143(3)

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

M/S TIMKEN ENGINEERING & RESEARCH INDIA P. LTD. vs. DCIT,

In the result, the appeal of the revenue is partly allowed in the terms indicated above

ITA 335/BANG/2013[2008-09]Status: DisposedITAT Bangalore10 May 2019AY 2008-09

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Aliasger Rampurawala, CAFor Respondent: Shri B.K. Panda, CIT (DR)
Section 133(6)Section 143(3)

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

DCIT vs. M/S TIMKEN ENGINEERING AND RESEARCH PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

ITA 469/BANG/2013[2007-08]Status: DisposedITAT Bangalore10 May 2019AY 2007-08

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

For Appellant: Shri Aliasger Rampurawala, CAFor Respondent: Shri B.K. Panda, CIT (DR)
Section 133(6)Section 143(3)

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

ASST.C.I.T., BANGALORE vs. M/S AMETEK INSTRUMENTS INDIA PRIVATE LIMITED, BANGALORE

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

ITA 398/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Sept 2021AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A No.398/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Sharath Rao, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(5)Section 92B

section 143(1) of the Act and the case was selected for scrutiny. The Assessing Officer ("AO") made a reference to the Transfer Pricing Officer ("TPO") to determine the arm's length price ("ALP") of the international transactions of the Assessee with its Associated Enterprises ("AE"). 7.1. AS PER TRANSFER PRICING ("TP") STUDY: For the subject

AMETEK INSTRUMENTS INDIA PVT. LTD.,,BANGALORE vs. ASST.C.I.T., BANGALORE

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

ITA 499/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Sept 2021AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A No.398/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Sharath Rao, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(5)Section 92B

section 143(1) of the Act and the case was selected for scrutiny. The Assessing Officer ("AO") made a reference to the Transfer Pricing Officer ("TPO") to determine the arm's length price ("ALP") of the international transactions of the Assessee with its Associated Enterprises ("AE"). 7.1. AS PER TRANSFER PRICING ("TP") STUDY: For the subject

M/S TALLY SOLUTIONS PVT. LTD.,,BANGALORE vs. ACIT, BANGALORE

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

ITA 1364/BANG/2011[2007-08]Status: DisposedITAT Bangalore19 Aug 2016AY 2007-08

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

For Appellant: Shri Arvind Sonde, Senior CounselFor Respondent: Smt. Neera Malhotra, CIT-II (D.R)
Section 143(3)Section 928Section 92C

section 928 of the Act and therefore no adjustment was warranted under chapter X of the Act. ix) ignoring the fact that the TPO adopted the notional interest receivable at a rate as high as 14% p.a, which is totally arbitrary, to quantify an adjustment to the arms length price, towards interest receivable. x) ignoring that the TPO adopted notional

DCIT, BANGALORE vs. M/S TOYOTA KIRLOSKAR AUTO PARTS LIMITED, BANGALORE

In the result, the assessee’s appeal is dismissed, while the revenue’s appeal is partly allowed

ITA 1029/BANG/2014[2005-06]Status: DisposedITAT Bangalore22 Dec 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT)-II, Bengaluru
Section 37Section 92C

section 37 (1) of the Income Tax Act, 1961 (the Act). 11. The learned AO and the Hon'ble CIT (A) erred in concluding that the Appellant is providing for warranty on an adhoc basis and not on scientific method. 12. The learned AO and the Hon'ble CIT (A) erred in disallowing the warranty expenses without considering the details

TOYOTA KIRLOSKAR AUTO PARTS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal is dismissed, while the revenue’s appeal is partly allowed

ITA 1024/BANG/2014[2005-06]Status: DisposedITAT Bangalore22 Dec 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT)-II, Bengaluru
Section 37Section 92C

section 37 (1) of the Income Tax Act, 1961 (the Act). 11. The learned AO and the Hon'ble CIT (A) erred in concluding that the Appellant is providing for warranty on an adhoc basis and not on scientific method. 12. The learned AO and the Hon'ble CIT (A) erred in disallowing the warranty expenses without considering the details

DCIT vs. M/S CONTROL COMPONENT (I) PVT. LTD.,,

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

ITA 1757/BANG/2013[2009-10]Status: DisposedITAT Bangalore09 Nov 2016AY 2009-10

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri. P. K. Prasad &For Respondent: Shri. D. Sudhakar Rao, CIT-DR
Section 143Section 143(3)Section 92C

transfer pricing adjustment in respect of ITeS services as follows: IT(TP)A No.1757/Bang/2013 & IT(TP) No.4/Bang/2014 Page 7 of 22 7. The assessing officer passed draft order dated 05.03.2013 u/s. 143 incorporating the above adjustments and also disallowing the claim u/s 10A to the extent of Rs.23,28,704/- in respect of travel and communication expenditure incurred reducing

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

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 1315/BANG/2010[2006-07]Status: DisposedITAT Bangalore31 Mar 2015AY 2006-07

Bench: Smt. P. Madhavi Devi & Shri Jason P.Boaz

For Appellant: Shri B.R.Sudheendra, CAFor Respondent: Shri C.H.Sundar Rao, CIT (DR)
Section 143(3)Section 92

section 92CA of the Income-tax Act, the adjustment as proposed originally in the letter dated 03.11.2006 has been sustained in its entirety. It was submitted that the letter dated 03.11.2006 was drafted even without an opportunity of being heard personally being given to the assessee and even without the requisite details being on record. In other words, the letter

M/S FINANCIAL OBJECTS SOFTWARE (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, this appeal is partly allowed

ITA 1471/BANG/2012[2008-09]Status: DisposedITAT Bangalore20 Sept 2019AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Vikram Singh Yadav, Accountant Membe

For Appellant: Shri K.R. Pradeep, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)(ITAT) Bangalore
Section 133(6)Section 143(3)

transfer pricing order without issue of any notice; 1.6. if TNMM is applied, the margins will be within +/-5 percent range at ALP; and 1.7. Has not provided the working capital adjustment and selling and marketing adjustment under CPM and a contrary position has been adopted against the position approved in the preceding years by the Honourable