BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

161 results for “transfer pricing”+ Section 10(35)clear

Sorted by relevance

Delhi2,742Mumbai2,389Bangalore1,069Chennai496Ahmedabad478Kolkata421Hyderabad407Karnataka360Pune309Jaipur297Chandigarh227Surat206Indore186Cochin161Rajkot79SC64Visakhapatnam58Calcutta55Raipur51Telangana50Lucknow48Cuttack47Nagpur34Guwahati25Jodhpur22Amritsar21Agra14Dehradun11Ranchi9Varanasi9Rajasthan8Kerala7Panaji6Patna6A.K. SIKRI ROHINTON FALI NARIMAN5Allahabad5Orissa5MADAN B. LOKUR S.A. BOBDE1Jabalpur1A.K. SIKRI N.V. RAMANA1Andhra Pradesh1Punjab & Haryana1DIPAK MISRA V. GOPALA GOWDA1T.S. THAKUR ROHINTON FALI NARIMAN1D.K. JAIN JAGDISH SINGH KHEHAR1

Key Topics

Section 25092Addition to Income35Section 143(3)22Section 9(1)(vii)16Capital Gains13Section 80G12Exemption10Section 153A9Disallowance9

APOLLO TYRES LTD.,COCHIN vs. DCIT CORPORATE CIR 1(1), KOCHI

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 679/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Sept 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 154Section 35Section 92C

35(2AB). 6. Regarding incorrect addition of Rs. 29.88 crs made in Book Profit: The Ld. AO erred in law and on facts, in considering Deemed Total Income (Book Profit) u/s 115JB of the Act at Rs. 617,40,70.233/- as against the correct returned 7 Apollo Tyres Ltd. amount of Rs. 587,52,13,537/-, This has resulted

Showing 1–20 of 161 · Page 1 of 9

...
Section 2(24)(vi)8
Section 488
Section 1327

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

Transfer Pricing Officer (TPO) u/s. 92CA(1) of the Act for the purpose of benchmarking the above international transactions. The TPO vide order dated 28.10.2016 3 Apollo Tyres Ltd. passed u/s. 92CA(3) of the Act suggested upward TP adjustments in respect of corporate guarantee commission provided to Apollo Vredestein BV (AVBV

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. 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.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

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.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

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

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 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

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.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

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

In the result, the appeals of the assessesin ITA no

ITA 27/COCH/2019[2004-05]Status: DisposedITAT Cochin30 Sept 2019AY 2004-05

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

10,40,470/- out of Rs.25,40,470/- received as sale consideration of rubber estate per acre formed part of consideration in lieu of relinquishment of trusteeship, the assessing officer and the CIT(A) had ignored the agreement dated 01/06/2010 where in the parties to the agreement had decided to amend the clauses in the agreement dated 10/03/2009 relating

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

In the result, the appeals of the assessesin ITA no

ITA 31/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

10,40,470/- out of Rs.25,40,470/- received as sale consideration of rubber estate per acre formed part of consideration in lieu of relinquishment of trusteeship, the assessing officer and the CIT(A) had ignored the agreement dated 01/06/2010 where in the parties to the agreement had decided to amend the clauses in the agreement dated 10/03/2009 relating

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

In the result, the appeals of the assessesin ITA no

ITA 32/COCH/2019[2004-05]Status: DisposedITAT Cochin30 Sept 2019AY 2004-05

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

10,40,470/- out of Rs.25,40,470/- received as sale consideration of rubber estate per acre formed part of consideration in lieu of relinquishment of trusteeship, the assessing officer and the CIT(A) had ignored the agreement dated 01/06/2010 where in the parties to the agreement had decided to amend the clauses in the agreement dated 10/03/2009 relating

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

In the result, the appeals of the assessesin ITA no

ITA 29/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

10,40,470/- out of Rs.25,40,470/- received as sale consideration of rubber estate per acre formed part of consideration in lieu of relinquishment of trusteeship, the assessing officer and the CIT(A) had ignored the agreement dated 01/06/2010 where in the parties to the agreement had decided to amend the clauses in the agreement dated 10/03/2009 relating

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

10,40,470/- out of Rs.25,40,470/- received as sale consideration of rubber estate per acre formed part of consideration in lieu of relinquishment of trusteeship, the assessing officer and the CIT(A) had ignored the agreement dated 01/06/2010 where in the parties to the agreement had decided to amend the clauses in the agreement dated 10/03/2009 relating