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5 results for “TDS”+ Section 144C(6)(C)clear

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Key Topics

Section 144C8Section 143(3)5Section 405Section 144C(5)4Disallowance4Section 92C3Addition to Income3Section 115J2Section 352Section 234B

IFTHIKAR KARUPPAMVEETIL ABDUL RAHMAN,CHAVAKKAD vs. ITO, INTERNATIONAL TAXATION, KOCHI

Appeal is partly allowed in above terms

ITA 119/COCH/2024[2018-2019]Status: DisposedITAT Cochin25 Sept 2024AY 2018-2019

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Ms. Divya Ravindran, AdvocateFor Respondent: Sri Dr. S. Pandian, CIT-DR
Section 143(3)Section 144ASection 144CSection 144C(15)(b)Section 147Section 56Section 57

C. It is submitted that the Amendment to Section 144C (15)(b)(ii) was vide Finance Act, 2020, is by way of a substitution. Non- residents who were not eligible assessees under Section 144C of the Act prior to 31.03.2020, were brought within the ambit of the Section, w.e.f 01.04.2020 only. Insofar as a non- resident is concerned

2
Transfer Pricing2
Deduction2

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

144C(13) of the Income Tax Act, 1961('the Act') by 8 Apollo Tyres Ltd. the Assessing Officer (AO') pursuant to the directions of the Dispute Resolution Panel (DRP) and the additions/disallowances made by the AO are illegal, bad in law and without jurisdiction. 2. The additions/disallowances made are unsustainable, unjust, highly excessive and are not based on any material

M/S.ALLIANZ CORNHILL INFORMATION SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, ground Nos

ITA 489/COCH/2016[2012-13]Status: DisposedITAT Cochin24 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S, AdvocateFor Respondent: Sri. Santhom Bose, CIT-DR
Section 143(2)Section 143(3)Section 144C(2)(b)Section 156Section 2Section 36(1)(va)Section 40

144C r.w.s. 92CA of the I.T.Act and issued the demand notice u/s 156 of the Act raising a total demand of Rs.9,38,08,666. 2.4 Aggrieved by the final assessment order, the assessee company has filed the present appeal and the stay application before the Tribunal. The synopsis of the grounds argued by the learned Counsel for the assessee

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

144C(5) of the I.T.Act, dated 28.12.2015. Since common issues are involved in both the appeals, they are being heard together and disposed off by this consolidated order, for the sake of convenience. 2. Grounds of appeal raised in ITA No.475/Coch/2016 are reproduced below:- “The grounds stated hereunder are independent of, and without prejudice to one another. The Appellant submits

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

144C(5) of the I.T.Act, dated 28.12.2015. Since common issues are involved in both the appeals, they are being heard together and disposed off by this consolidated order, for the sake of convenience. 2. Grounds of appeal raised in ITA No.475/Coch/2016 are reproduced below:- “The grounds stated hereunder are independent of, and without prejudice to one another. The Appellant submits