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6 results for “disallowance”+ Section 92C(3)clear

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Key Topics

Section 144C(5)12Disallowance6Section 92C(2)4Section 404Transfer Pricing4Section 10B2Section 143(3)2Section 2532Section 92C2Section 144C

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)

section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly, the learned AO erred in not demonstrating that the motive of the Appellant was to shift profits outside

2
Comparables/TP2
Addition to Income2

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)

section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly, the learned AO erred in not demonstrating that the motive of the Appellant was to shift profits outside

ACIT CORPORATE, COCHIN vs. M/S.JOY ALUKKAS (INDIA) LTD, COCHIN

In the result, the appeal of the assessee is dismissed and the appeal of the

ITA 151/COCH/2015[2010-11]Status: DisposedITAT Cochin09 Apr 2018AY 2010-11

Bench: S/Shri Chandra Poojari , Am & George George K., Jm

Section 143(3)Section 144CSection 144C(5)Section 253Section 36(1)Section 36(1)(iii)Section 92CSection 92C(2)

3. The Dispute Resolution Panel failed to note that as per section 92C(2), as applicable to the relevant year, if the variation between ALP and the price at which the international transaction had been undertaken is less than 5%, then no adjustment towards ALP is called for. 4. The Assistant Commissioner of Income Tax / Dispute Resolution Panel

M/S.JOY ALUKKAS INDIA P LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeal of the assessee is dismissed and the appeal of the

ITA 190/COCH/2015[2010-11]Status: DisposedITAT Cochin09 Apr 2018AY 2010-11

Bench: S/Shri Chandra Poojari , Am & George George K., Jm

Section 143(3)Section 144CSection 144C(5)Section 253Section 36(1)Section 36(1)(iii)Section 92CSection 92C(2)

3. The Dispute Resolution Panel failed to note that as per section 92C(2), as applicable to the relevant year, if the variation between ALP and the price at which the international transaction had been undertaken is less than 5%, then no adjustment towards ALP is called for. 4. The Assistant Commissioner of Income Tax / Dispute Resolution Panel

THE JT CIT, TRIVANDRUM vs. ALLIANZ CORNHILL INFORMATION SERVICES P. LTD, TRIVANDRUM

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

ITA 185/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

92C(2) of the Act. 8. Disallowance of tax holiday section 10B of the Act On the facts and in the circumstances of the case and in law, the learned Joint Commissioner of Income-tax ("JCIT") on direction made by the Dispute Resolution Panel ('DRP') has erred in disallowing Rs. I4,19,80,333/- claimed by the Company as deduction

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

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

ITA 191/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

92C(2) of the Act. 8. Disallowance of tax holiday section 10B of the Act On the facts and in the circumstances of the case and in law, the learned Joint Commissioner of Income-tax ("JCIT") on direction made by the Dispute Resolution Panel ('DRP') has erred in disallowing Rs. I4,19,80,333/- claimed by the Company as deduction