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13 results for “transfer pricing”+ Section 201(1)clear

Sorted by relevance

Mumbai350Delhi219Chennai81Bangalore79Jaipur61Hyderabad45Kolkata19Jodhpur17Ahmedabad16Pune14Cochin13Chandigarh13Indore9Cuttack9Lucknow8Visakhapatnam5Rajkot5Surat5Varanasi5Guwahati4Nagpur2Dehradun2Amritsar2Jabalpur2Allahabad1

Key Topics

Section 9(1)(vii)20Section 2(15)16Section 143(3)12Exemption7Section 1325Section 153A5Section 153C5Section 2015Section 1955

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 addition of Rs. 9,57,364/- to the income of the Assessee and holding that the international transactions pertaining to provision of corporate IT services do not satisfy the arm's length principle envisaged under the Act. 12.3 On the facts and in the circumstances of the case and in law, the Ld. AO/Ld. ΤΡΟ grossly erred

Double Taxation/DTAA5
TDS5

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)

201 on the ground that the\nThe Deputy\nCommissioner of\nIncome Tax,\nCorporate Circle\n1(1),\nCochin\nVs.\nRESPONDENT\nPage 3 of 8\nITA Nos. 720 to 724/Coch/2023\nassessee had not deducted tax at source u/s. 195 of the Act as against the\npayments made to the said two entities on the ground that the said non\nresidents have business

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)

201 on the ground that the\nassessee had not deducted tax at source u/s. 195 of the Act as against the\npayments made to the said two entities on the ground that the said non\nresidents have business connection in India. The assessee's appeal was also\ndismissed by the Ld.CIT(A). Thereafter the assessee filed an appeal before\nthe

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

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

ITA 212/COCH/2019[2010-11]Status: DisposedITAT Cochin22 May 2025AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

MRS.REENA JOSE,PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE,, KOTTAYAM

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

ITA 207/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

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

ITA 208/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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

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

ITA 209/COCH/2019[2010-11]Status: DisposedITAT Cochin22 May 2025AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

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

ITA 211/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

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)

201 on the ground that the Page 3 of 8 ITA Nos. 720 to 724/Coch/2023 assessee had not deducted tax at source u/s. 195 of the Act as against the payments made to the said two entities on the ground that the said non residents have business connection in India. The assessee’s appeal was also dismissed by the Ld.CIT

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)

201 on the ground that the Page 3 of 8 ITA Nos. 720 to 724/Coch/2023 assessee had not deducted tax at source u/s. 195 of the Act as against the payments made to the said two entities on the ground that the said non residents have business connection in India. The assessee’s appeal was also dismissed by the Ld.CIT

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)

201 on the ground that the Page 3 of 8 ITA Nos. 720 to 724/Coch/2023 assessee had not deducted tax at source u/s. 195 of the Act as against the payments made to the said two entities on the ground that the said non residents have business connection in India. The assessee’s appeal was also dismissed by the Ld.CIT

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 632/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

201 7. held that "The newly Inserted Proviso to Section 2(15) will not apply in respect of the First Three limbs of Sec.2(15), ie relief of poor, education or medical relief. Consequently where the purpose of a trust or institution is relief of poor, education or medical relief it will ITA NoS.632 & 633/Coch/2022 Page 8 of 12 constitute

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 633/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

201 7. held that "The newly Inserted Proviso to Section 2(15) will not apply in respect of the First Three limbs of Sec.2(15), ie relief of poor, education or medical relief. Consequently where the purpose of a trust or institution is relief of poor, education or medical relief it will ITA NoS.632 & 633/Coch/2022 Page 8 of 12 constitute