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6 results for “transfer pricing”+ Permanent Establishmentclear

Sorted by relevance

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Key Topics

Section 9(1)(vii)12Section 92C7Section 14A6Double Taxation/DTAA5Section 36(1)(iii)4Section 143(3)3Section 2013Section 1953Section 9(1)(i)

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

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

establish that the INR.1.37 Crore represented reimbursement of expense received from AEs on cost to cost basis. No third party evidence were furnished by the Assessee. The DRP has also concurred with the TPO on this issue. Before us, the Learned Authorised Representative for the Assessee reiterated that the expenses were recovered from AEs on cost to cost basis

3
Transfer Pricing3
Disallowance3
Addition to Income3

THE DCIT, KOCHI vs. M/S.NETWORK SYSTEMS & TECHNOLOGIES P. LTD, ALUVA

In the result, the appeals filed by the Revenue stand partly allowed

ITA 2/COCH/2021[2012-13]Status: DisposedITAT Cochin27 Jun 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: Shri Anil D. Nair, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 143(3)Section 14ASection 36(1)(iii)Section 40Section 40aSection 92C

Transfer Pricing Officer (TPO) u/s. 92CA(3) of the Income Tax Act, 1961 (the Act) for the purpose of benchmarking the above international transactions. The TPO, vide order dated Nretwrok Systems & Technologies P. Ltd. 29.01.2016 pass u/s. 92CA of the Act suggested upward adjustment in respect of commission on post services offered paid to Nihon Nest Corporation

THE DCIT, KOCHI vs. M/S.NETWORK SYSTEMS & TECHNOLOGIES P. LTD, ALUVA

In the result, the appeals filed by the Revenue stand partly allowed

ITA 3/COCH/2021[2013-14]Status: DisposedITAT Cochin27 Jun 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm

For Appellant: Shri Anil D. Nair, AdvocateFor Respondent: Shri Sundarasan S., CIT-DR
Section 143(3)Section 14ASection 36(1)(iii)Section 40Section 40aSection 92C

Transfer Pricing Officer (TPO) u/s. 92CA(3) of the Income Tax Act, 1961 (the Act) for the purpose of benchmarking the above international transactions. The TPO, vide order dated Nretwrok Systems & Technologies P. Ltd. 29.01.2016 pass u/s. 92CA of the Act suggested upward adjustment in respect of commission on post services offered paid to Nihon Nest Corporation

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

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

ITA 721/COCH/2023[2006-07]Status: DisposedITAT Cochin23 Sept 2025AY 2006-07

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

permanent establishment in India. The Ld.CIT(A) had relied on the order of the Hon’ble Bangalore Bench of the Tribunal in the case of ABB-Fz LLC which was given by following the another order of the Hon’ble Bangalore Tribunal in the case of IBM India Pvt. Ltd. vs. DDIT. 6. As against the said order

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

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

ITA 723/COCH/2023[2008-09]Status: DisposedITAT Cochin23 Sept 2025AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

permanent establishment in India. The Ld.CIT(A) had relied on the order of the Hon’ble Bangalore Bench of the Tribunal in the case of ABB-Fz LLC which was given by following the another order of the Hon’ble Bangalore Tribunal in the case of IBM India Pvt. Ltd. vs. DDIT. 6. As against the said order

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

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

ITA 724/COCH/2023[2009-10]Status: DisposedITAT Cochin23 Sept 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

permanent establishment in India. The Ld.CIT(A) had relied on the order of the Hon’ble Bangalore Bench of the Tribunal in the case of ABB-Fz LLC which was given by following the another order of the Hon’ble Bangalore Tribunal in the case of IBM India Pvt. Ltd. vs. DDIT. 6. As against the said order