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8 results for “transfer pricing”+ Section 10Aclear

Sorted by relevance

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Key Topics

Section 10B13Section 10A9Section 143(3)8Section 2637Section 144C(5)6Transfer Pricing6Disallowance5Comparables/TP5Section 404Deduction

THE JT CIT, TRIVANDRUM vs. ALLIANZ CORNHILL INFORMATION SERVICES P. LTD, TRIVANDRUM

In the result, the appeal of the assessee is partly allowed and the

ITA 185/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

transfer pricing policy of the Assessee. 3 Determination of arm's length price by the TPO in relation to the ‘Software Development Services’ segment • The TPO erred in law in not rejecting certain companies originally selected as comparables in the TP study even though the underlying functional/ business profile of those companies squarely disqualified them being comparables. 3 & 185/Coch/2015

M/S.ALLIANZ CORNHILL INFORMATION SERVICES P. LTD,TRIVANDRUM vs. JTCIT, TRIVANDRUM

In the result, the appeal of the assessee is partly allowed and the

4
Section 144C3
Addition to Income3
ITA 191/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

transfer pricing policy of the Assessee. 3 Determination of arm's length price by the TPO in relation to the ‘Software Development Services’ segment • The TPO erred in law in not rejecting certain companies originally selected as comparables in the TP study even though the underlying functional/ business profile of those companies squarely disqualified them being comparables. 3 & 185/Coch/2015

M/S.REVENUE MED INDIA (P) LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the additional ground raised is allowed for statistical purposes

ITA 146/COCH/2015[2010-11]Status: DisposedITAT Cochin06 Sept 2018AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S, AdvocateFor Respondent: Sri.Santham Bose
Section 10ASection 10BSection 143(3)

section 10A of the Act.” Additional Ground: 2.1 On the facts and circumstances of the case and in law, the learned A.O./TPO erred in computation of operating profit margins of the tested party. IT(TP)A No.144 & 146/Coch/2015 3 SA No.25/Coch/2018. M/s.Navigant BPM (India) Pvt.Ltd. 4. We shall adjudicate the above grounds as follows:- Ground No. 7.1 (Transfer Pricing

ACIT, TRIVANDRUM vs. REVENUED(INDIA) P. LTD, TRIVANDRUM

In the result, the additional ground raised is allowed for statistical purposes

ITA 144/COCH/2015[2010-11]Status: DisposedITAT Cochin06 Sept 2018AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S, AdvocateFor Respondent: Sri.Santham Bose
Section 10ASection 10BSection 143(3)

section 10A of the Act.” Additional Ground: 2.1 On the facts and circumstances of the case and in law, the learned A.O./TPO erred in computation of operating profit margins of the tested party. IT(TP)A No.144 & 146/Coch/2015 3 SA No.25/Coch/2018. M/s.Navigant BPM (India) Pvt.Ltd. 4. We shall adjudicate the above grounds as follows:- Ground No. 7.1 (Transfer Pricing

M/S.NAVIGANT BPM (INDIA) P. LTD(EARLIER KNOWN AS REVENUE MED INDIA P. LTD),TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, ground No.4

ITA 57/COCH/2016[2011-12]Status: DisposedITAT Cochin23 Oct 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan SFor Respondent: Smt.A.S.Bindhu, Sr.DR
Section 10ASection 10BSection 14Section 143(3)Section 144C

sections 10A and 10B of the I.T.Act are pari materia. In view of the above judicial pronouncement, we deem it appropriate to remit the issue to the Assessing Officer for fresh consideration. The Assessing Officer shall follow the dictum laid down by the above mentioned judicial pronouncements and shall grant deduction u/s 10A of the I.T.Act provided the conditions

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

section 40(a)(ia) of the I.T.Act, as it was considered retrospective effect by the Hon’ble Supreme Court in the case of Calcutta Export Company (supra). Accordingly, this issue is remitted to the file of A.O. for fresh consideration. 14. As regards ground No.6 and its sub-grounds, the grievance of the assessee is that the Transfer Pricing Officer

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

section 40(a)(ia) of the I.T.Act, as it was considered retrospective effect by the Hon’ble Supreme Court in the case of Calcutta Export Company (supra). Accordingly, this issue is remitted to the file of A.O. for fresh consideration. 14. As regards ground No.6 and its sub-grounds, the grievance of the assessee is that the Transfer Pricing Officer

M/S.US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE JCIT, TRIVANDRUM

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

ITA 247/COCH/2017[2009-10]Status: DisposedITAT Cochin23 Jul 2018AY 2009-10

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.M.Raghunathan SFor Respondent: Sri.Santam Bose
Section 10ASection 10BSection 143(1)Section 143(3)Section 144CSection 263

transfer pricing adjustment in the draft assessment order. The final assessment order was passed on 26.04.2013. The assessee, however, claims that the final assessment order was not received by it. Thereafter reassessment notice was issued and orders u/s 143(3) r.w.s. 147 of the I.T.Act was passed on 27.03.2015. The Assessing Officer in the reassessment completed, disallowed the amount claimed