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10 results for “transfer pricing”+ Reassessmentclear

Sorted by relevance

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Key Topics

Section 408Reassessment8Disallowance7Section 40A(2)(b)6Section 36(1)(viia)5Section 80H5Section 40A(3)4Section 270A(1)2Section 271(1)(c)2Section 80I

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

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

ITA 141/COCH/2021[2000-2001]Status: DisposedITAT Cochin17 Jan 2024AY 2000-2001

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(1)Section 148(1)Section 271(1)(c)Section 274Section 80Section 801A(9)Section 80HSection 80I

transfers to sister concerns, the value of tins was already embedded in the sale price, an issue decided by the first Appellate authority in favour of the assessee. (emphasis, ours) 4. The assessee thus failing to improve his case in any manner, penalty was levied for the same reasons, finding the assessee’s offer of an additional sum of Rs.180.40

2
Deduction2
Penalty2

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

ITA 171/COCH/2024[2018-2019]Status: DisposedITAT Cochin11 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Dijo Mathew, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(2)Section 270ASection 270A(1)Section 270A(2)Section 36(1)(viia)Section 40

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

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

transferred to the securities premium account. It may be that the expenditure finally booked for the relevant year accounts for this difference, as it appears from a reading of Note 2.1(o). Further, the valuation of the options unexercised as at the end of the account period, inasmuch as it would only be with reference to the extant market price

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 627/COCH/2022[2009-2010]Status: DisposedITAT Cochin31 Aug 2023AY 2009-2010

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 623/COCH/2022[2004-2005]Status: DisposedITAT Cochin31 Aug 2023AY 2004-2005

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

M/S SULAIKHA CLAY MINES,TRIVANDRUM vs. DCIT ,CIRCLE 1(2), TRIVANDRUM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 937/COCH/2022[2015-16]Status: DisposedITAT Cochin31 Aug 2023AY 2015-16

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 624/COCH/2022[2005-2006]Status: DisposedITAT Cochin31 Aug 2023AY 2005-2006

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 625/COCH/2022[2006-2007]Status: DisposedITAT Cochin31 Aug 2023AY 2006-2007

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

ITA 626/COCH/2022[2007-2008]Status: DisposedITAT Cochin31 Aug 2023AY 2007-2008

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Muhammad Shafeeq A., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 40Section 40A(2)(b)

reassessment (for Assessment Years (AYs.) 2004-05 to 2007-08) and regular assessments for the subsequent two years, challenging the same on confirmation in first appeal vide orders dated 28.12.2021 (AYs 2004-05 to 2006-07), 27.3.2022 (for AYs 2007-08 & 2009-10) and 31.8.2022 (for AY 2015-16), by the National Faceless Appeal Centre, Delhi (NFAC) or the First

M/S THE REGIONAL AGRO INDUSTRIAL DEVELOPMENT COOPERATIVE OF KERALA LTD,KANNUR vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KANNUR RANGE

ITA 563/COCH/2025[2010-11]Status: DisposedITAT Cochin18 Nov 2025AY 2010-11

Bench: The Tribunal Within The Time Prescribed. Accordingly, The Delay Of 69 Days In Filing The Present Appeal Is Condoned.

For Appellant: Shri Suresh KumarFor Respondent: Smt. Leena Lal
Section 143(3)Section 147Section 148Section 250Section 40A(3)

Reassessment proceedings were initiated in the case of the Assessee by issuance of notice dated 25/10/2012 under Section 148 of the Act. In response to the aforesaid notice Assessee filed return of income on 17/01/2013 declaring ‘Nil’ income. During the assessment proceedings the Assessing Officer noted that payment aggregating of INR.72,30,560/- were made in cash during the relevant