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168 results for “transfer pricing”+ Section 10(20)clear

Sorted by relevance

Delhi3,945Mumbai3,799Bangalore1,593Chennai729Kolkata632Ahmedabad602Hyderabad576Pune536Karnataka450Jaipur397Chandigarh281Surat271Indore241Cochin168Rajkot105Visakhapatnam98SC93Cuttack78Telangana77Nagpur68Calcutta64Lucknow62Raipur59Amritsar40Agra32Jodhpur29Dehradun27Guwahati27Ranchi13A.K. SIKRI ROHINTON FALI NARIMAN13Varanasi9Rajasthan9Panaji9Jabalpur8Kerala7Allahabad7Orissa6Patna6Punjab & Haryana2MADAN B. LOKUR S.A. BOBDE1T.S. THAKUR ROHINTON FALI NARIMAN1DIPAK MISRA V. GOPALA GOWDA1D.K. JAIN JAGDISH SINGH KHEHAR1Andhra Pradesh1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 25092Addition to Income33Section 80G28Section 143(3)16Section 80G(5)10Capital Gains9Section 153A8Section 2(24)(vi)8Section 48

TORRY HARRIS SEA FOODS LTD,ALAPPUZHA vs. THE ACIT, ALAPPUZHA

In the result, the appeal filed by the assessee is dismissed

ITA 447/COCH/2016[2012-13]Status: DisposedITAT Cochin05 Jul 2018AY 2012-13

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

Section 143(3)Section 144C(5)

transfer pricing provisions. You have claimed uniform adjustments @ 3% in all cases, without providing any clear rationale for the same. Adjustments have been claimed in an arbitrary manner without any factual and scientific basis being given. 'You have not submitted the quantification process adopted by you to arrive at the adjustments, claimed. The fact is that 3% adjustment was claimed

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)

Showing 1–20 of 168 · Page 1 of 9

...
8
Section 92C8
Exemption8
Disallowance8
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

20,89,535/- x 5 Assessment Year 2013-2014 17.475%] in respect of notional interest on loans/advances. 5.4. Adopting identical reasoning, the TPO also proposed transfer pricing adjustment of INR.29,24,87,928/- in respect of interest on outstanding receivables [INR.167,37,50,666/- x 17.475%]. Before the TPO the Assessee had contended that no notional interest was required

SILLS KARINGATTIL JOSE,NEDUMKANDOM vs. ITO WARD 2, THODUPUZHA

Appeal is partly allowed for statistical purpose

ITA 132/COCH/2023[2016-17]Status: DisposedITAT Cochin19 Nov 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsils Karingattil Jose Income Tax Officer Np 3/406, Karingattil Ward - 2, House, Munnar Road Thodupuzha Vs. Nedumkandom P.O. [Pan: Afopj8789C] (Appellant) (Respondent)

For Appellant: Shri P. M. Veeramani, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 2(47)Section 2(47)(V)Section 250Section 50CSection 53ASection 56(2)(vii)

20) of section 10 ; or (f) from any fund or foundation or university or other educational institution or hospital or other medical institution or any trust or institution referred to in clause (23C) of section 10 ; or (g) from any trust or institution registered under section 12AA ; or (h) by way of transaction not regarded as transfer under clause (vicb

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

20,03,669/- (Vide Schedule to Fixed assets) No. of bags processed in Andhra Pradesh - 18,563 nos. Depreciation per kg.- Rs.5.33 Administrative Overheads (estimated) - Rs. 10/- per kg. So, total cost - Rs.228/- This is taken as the step up price after taking cognizance of lower grades comprised in these transfers as is evident from the break-up list enclosed

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes

ITA 562/COCH/2022[2017-2018]Status: DisposedITAT Cochin21 Oct 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 144C(3)Section 92C(3)

section 234B and 234C of the Act The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the appeal.” 3. At the outset, we note that the learned AR for the assessee before us submitted that issue raised by the assessee in ground

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 49/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 40/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 43/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 44/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 48/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 38/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 42/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.K.RAVINDRANATHAN NAIR,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 46/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 45/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 39/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 37/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 47/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 41/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 28/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 34/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting