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61 results for “transfer pricing”+ Section 172(4)clear

Sorted by relevance

Mumbai239Delhi131Hyderabad72Chennai65Cochin61Chandigarh59Jaipur48Bangalore45Raipur19Surat14Ahmedabad12Nagpur10Indore10Agra8Kolkata7Varanasi5Lucknow4Rajkot4Cuttack3Pune2Jodhpur2Dehradun1Allahabad1Guwahati1

Key Topics

Section 250114Section 92C6Section 143(3)3Section 1472Section 133A2Section 1482Section 36(1)(iii)2Section 115J2Survey u/s 133A2

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

172/- with its Associated Enterprises. The case of the Assessee was referred to the Transfer Pricing Officer (TPO) under Section 92CA of the Act for determination of the Arm's Length Price (ALP) in relation to the said international transactions. TPO passed order, dated 28/10/2016, under Section 92CA(3) of the Act proposing an upward transfer pricing adjustment of INR.31

Showing 1–20 of 61 · Page 1 of 4

Limitation/Time-bar2
Transfer Pricing2
Disallowance2

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

ABC SALES CORPORATION,KASARAGOD vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 439/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 504/COCH/2024[2020-21]Status: DisposedITAT Cochin20 Dec 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT CENTRAL CIRCLE-1, CALICUT

In the result, appeal of the assessee is hereby dismissed

ITA 505/COCH/2024[2018-19]Status: DisposedITAT Cochin20 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT, CENTRAL CIRLCE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 506/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

BATHX BATHWARE INDIA PRIVATE LIMITED,COCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 438/COCH/2024[2016-2017]Status: DisposedITAT Cochin20 Dec 2024AY 2016-2017

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 497/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

A B C SALES CORPORATION ,KANNUR vs. ITO, CIRCLE-1, KANNUR

In the result, appeal of the assessee is hereby dismissed

ITA 404/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

BATHX BATHWARE INDIA PRIVATE LIMITED,KOCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 436/COCH/2024[2014-2015]Status: DisposedITAT Cochin20 Dec 2024AY 2014-2015

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC BUILDWARES INDIA(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 454/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC BUILDWARES(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1`, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 455/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC BUILDWAERS INDIA (P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 456/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 457/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 458/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 503/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 498/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 499/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 500/COCH/2024[2020-2021]Status: DisposedITAT Cochin20 Dec 2024AY 2020-2021

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

BATHX BATHWARE INDIA PRIVATE LIMITED,KOCHIN vs. ACIT, CENTRAL IRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 437/COCH/2024[2015-2016]Status: DisposedITAT Cochin20 Dec 2024AY 2015-2016

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming