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63 results for “transfer pricing”+ Carry Forward of Lossesclear

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Key Topics

Section 250114Section 143(3)4Addition to Income4Section 92C3Limitation/Time-bar3Section 1472Section 133A2Section 1482Section 144C2

APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

carried on by the Taxpayer. i. The Taxpayer has used certain inappropriate filters: Ambiguous Filters such as Rejecting companies Functionally not comparable/Product or service difference Companies, Rejecting the companies having net sales < 1 crore and >50 crores are not appropriate filters for a service industry according to the TPO. Further, use of filters such as non-availability of financial data

M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

Showing 1–20 of 63 · Page 1 of 4

Section 144C(5)2
Survey u/s 133A2
Transfer Pricing2
ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

transfer pricing adjustment of INR.23,71,760/- and restore this issue back to the file of Assessing Officer/TPO for denovo adjudication. The Assessee is directed to produce all relevant documents/detauks before the Assessing Officer/TPO to substantiate that transaction under consideration were on cost to cost basis and did not include any mark up. Thus, Ground No. 8 raised

MR.P.C.JOSE,,COCHIN vs. DCIT, COCHIN

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

ITA 54/COCH/2012[2008-09]Status: DisposedITAT Cochin23 Apr 2024AY 2008-09

Bench: Shri Sanjay Arora & Shri Manomohan Dasp.C. Jose Deputy Commissioner Of Prop. Brothers Agencies Income Tax, Circle-2(1) Jews Street Vs. Kochi Ernakulam 682031 [Pan: Abbpj8250F] (Appellant) (Respondent) Deputy Commissioner Of P.C. Jose Income Tax, Circle-2(1) Prop. Brothers Agencies Kochi Vs. Jews Street Ernakulam 682031 [Pan: Abbpj8250F] (Appellant) (Respondent)

For Appellant: ----- None -----For Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)

carrying a particular trade or vocation, may include an activity which may be called ‘quiescent’ (CIT vs. Calcutta National Bank Ltd. [1959] 37 ITR 171 (SC)). Even a single transaction can be amount a business (refer paras 2.1 to 2.4 of the assessment order). Denying exemption on the gain on sale of such land/s, it was computed as under: (para

V GUARD INDUSTRIES LIMITED,VENNALA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, KOCHI

In the result, the assessee’s appeal is partly allowed

ITA 63/COCH/2022[2016-2017]Status: DisposedITAT Cochin20 Mar 2023AY 2016-2017

Bench: Shri Sanjay Arora & Shri Sandeep Gosainv-Guard Industries Ltd. Principal Cit-1, 42/962, Vennala High School C R Building, I S Press Road, Vs. Road, Vennala, Kochi 682018 Ernakulam 682028 [Pan: Aaacv5492Q] (Appellant) (Respondent) Appellant By: Shri Anil D. Nair, Advocate Respondent By: Shri Prashant V.K., Cit-Dr Date Of Hearing: 01.02.2023 Date Of Pronouncement: 20.03.2023 O R D E R Per: Bench This Is An Appeal By The Assessee Challenging The Revision Of It’S Assessment Under Section 143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) Dated 28/12/2018 For Assessment Year (Ay) 2016-17 By The Principal Commissioner Of Income Tax-1, Kochi (‘Pr. Cit’ For Short) Vide Order U/S. 263 Dated 22/03/2021. 2. The Appeal, Filed On 08/03/2022, Though Delayed By 256 Days, Was Admitted In View Of The Blanket Condonation By The Apex Court In Suo Motu Wp(C) No.3/2020, Dated 10/01/2022, Excluding The Period From 15/3/2020 To 28/02/2022 In Reckoning The Delay In Computing Limitation Under Law & The Hearing Accordingly Proceeded With. The Assessee Is A Company Manufacturing Electrical Cables, Pumps, Solar Water Heaters, Etc. & Trading In Electrical & Electronic Goods. Revision Of It’S Impugned Assessment Is On Several Issues On Which The Revisionary Authority Found An Absence Or Lack Of Enquiry By The Assessing Officer

For Appellant: Shri Anil D. Nair, AdvocateFor Respondent: Shri Prashant V.K., CIT-DR
Section 143(3)Section 263

carry-forward for this year, forming part of the current year’s depreciation, reducing the open written down value (WDV) thereby. No issue therefore, in our view, arises for being considered by the AO. The Revenue has no case, with the ld. Pr. CIT having himself not made any adverse comment in the matter (para 6.1) 4.3 Issue

GOOD HOMES PVT LTD,KOCHI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 884/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

transfer of profit of one concern to the another, which cannot be. Why, Sri.GK himself, despite the assessee-appellant’s returning income, which includes loss, based on their operative data, would canvass for a uniform profit across all entities upon ignoring ERF, ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit Asso. P.Ltd. &Good Homes P.Ltd. v. Dy. CIT implying

AJIT ASSOCIATES PRIVATE LIMITED,ERNAKULAM vs. JCIT, CORPORATE RANGE - 1, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 870/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

transfer of profit of one concern to the another, which cannot be. Why, Sri.GK himself, despite the assessee-appellant’s returning income, which includes loss, based on their operative data, would canvass for a uniform profit across all entities upon ignoring ERF, ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit Asso. P.Ltd. &Good Homes P.Ltd. v. Dy. CIT implying

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT, CENTRAL CIRLCE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 506/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT CENTRAL CIRCLE-1, CALICUT

In the result, appeal of the assessee is hereby dismissed

ITA 505/COCH/2024[2018-19]Status: DisposedITAT Cochin20 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC SALES CORPORATION,KASARAGOD vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 439/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 498/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

A B C SALES CORPORATION ,KANNUR vs. ITO, CIRCLE-1, KANNUR

In the result, appeal of the assessee is hereby dismissed

ITA 404/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

BATHX BATHWARE INDIA PRIVATE LIMITED,KOCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 436/COCH/2024[2014-2015]Status: DisposedITAT Cochin20 Dec 2024AY 2014-2015

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC BUILDWARES INDIA(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 454/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC BUILDWARES(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1`, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 455/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 504/COCH/2024[2020-21]Status: DisposedITAT Cochin20 Dec 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 497/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 458/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 457/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

ABC BUILDWAERS INDIA (P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 456/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 503/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

forward by the revenue, primarily in the form of the investor agreement and Excel sheets, does not provide sufficient support for the allegations of undisclosed investments. 20.8 Furthermore, we note that, the AO's argument centers around the allegation that the ABC group made indirect investments in M/s ABC Mercantile FZC by routing investments through three existing companies