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9 results for “transfer pricing”+ Section 195(2)clear

Sorted by relevance

Delhi290Mumbai288Chennai94Bangalore94Jaipur54Hyderabad34Ahmedabad29Chandigarh25Rajkot21Kolkata14Pune13Lucknow12Nagpur9Cochin9Indore8Raipur8Cuttack6Varanasi5Visakhapatnam5Agra3Allahabad3Surat2Jabalpur2Jodhpur1Guwahati1

Key Topics

Section 9(1)(vii)20Exemption8Section 143(3)5Section 2015Section 1955Section 9(1)(i)5Double Taxation/DTAA5TDS5Addition to Income4

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

Section 12A3
Section 113
Section 2(15)3

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

ITA 76/COCH/2015[2010-11]Status: DisposedITAT Cochin11 Aug 2023AY 2010-11

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

section 2(15). However, the Court does not rule out any future claim made and being independently assessed, if GS1 is able to satisfy that what it provides to its customers is charged on cost-basis with at the most, a nominal mark-up. The foregoing neatly sums up the adjudication qua entities as the assessee, which is accordingly

INFOPARKS KERALA,COCHIN vs. THE ACIT, COCHIN

In the result, the assessee’s appeals are partly allowed

ITA 77/COCH/2015[2011-12]Status: DisposedITAT Cochin11 Aug 2023AY 2011-12

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

section 2(15). However, the Court does not rule out any future claim made and being independently assessed, if GS1 is able to satisfy that what it provides to its customers is charged on cost-basis with at the most, a nominal mark-up. The foregoing neatly sums up the adjudication qua entities as the assessee, which is accordingly

INFOPARKS KERALA,TRIVANDRUM vs. THE JT DIRECTOR OF IT (OSD) EXEM), COCHIN

In the result, the assessee’s appeals are partly allowed

ITA 75/COCH/2015[2009-10]Status: DisposedITAT Cochin11 Aug 2023AY 2009-10

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

section 2(15). However, the Court does not rule out any future claim made and being independently assessed, if GS1 is able to satisfy that what it provides to its customers is charged on cost-basis with at the most, a nominal mark-up. The foregoing neatly sums up the adjudication qua entities as the assessee, which is accordingly

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 722/COCH/2023[2007-08]Status: DisposedITAT Cochin23 Sept 2025AY 2007-08
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

2 of 8\nITA Nos. 720 to 724/Coch/2023\n2. All these appeals are related to the same assessee and the issue\ninvolved in all the appeals are similar and therefore we decided to take up all\nthe appeals together and pass a common order for the sake of convenience.\n3. We will take up the appeal in ITA No. 720/Coch/2023

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 720/COCH/2023[2005-06]Status: DisposedITAT Cochin23 Sept 2025AY 2005-06
For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

2 of 8\nITA Nos. 720 to 724/Coch/2023\n2. All these appeals are related to the same assessee and the issue\ninvolved in all the appeals are similar and therefore we decided to take up all\nthe appeals together and pass a common order for the sake of convenience.\n3. We will take up the appeal in ITA No. 720/Coch/2023

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 721/COCH/2023[2006-07]Status: DisposedITAT Cochin23 Sept 2025AY 2006-07

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

2. Whether on the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in holding that specialized knowledge and experience of procurement of goods for duty free shop was made available to the appellant by the Alpha Airport Holdings (UK) Ltd. The Ld. CIT(A) erred in holding that the services rendered by Alpha were

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 723/COCH/2023[2008-09]Status: DisposedITAT Cochin23 Sept 2025AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

2. Whether on the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in holding that specialized knowledge and experience of procurement of goods for duty free shop was made available to the appellant by the Alpha Airport Holdings (UK) Ltd. The Ld. CIT(A) erred in holding that the services rendered by Alpha were

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 724/COCH/2023[2009-10]Status: DisposedITAT Cochin23 Sept 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

2. Whether on the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in holding that specialized knowledge and experience of procurement of goods for duty free shop was made available to the appellant by the Alpha Airport Holdings (UK) Ltd. The Ld. CIT(A) erred in holding that the services rendered by Alpha were