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87 results for “transfer pricing”+ Section 254(1)clear

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Key Topics

Section 250114Addition to Income22Section 153A17Section 13213Exemption13Section 143(3)11Section 14A8Disallowance7Section 133A6

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

ITA 261/COCH/2016[2006-07]Status: DisposedITAT Cochin03 Oct 2017AY 2006-07

Bench: Shri P. K. Bansal & Shri George George K.

Section 132Section 143(1)Section 143(2)Section 153ASection 153CSection 234A

254 CTR (Del) 392 has taken similar view. In para 11 of this judgement, the Hon'ble High Court held that "obviously an assessment has to be made under this section only on the basis of the seized material". Even we noted that the Hon'ble Delhi High Court in the case of Anil Kumar Bhatia

Showing 1–20 of 87 · Page 1 of 5

Section 43B5
Section 50B4
Transfer Pricing3

M/S ASPINWALL & CO.,LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

ITA 128/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

254 ITR 377) (Delhi) 2) CIT vs. M/s. Walchand& Co. (Pvt.) Ltd. (65 ITR 381 (SC) 3) CIT vs. M/s. Edward Keventer (Private) Ltd. (115 ITR 149) (SC) 5.3 The Ld. AR submitted that disallowance computed u/s. 14A should not exceed the exempt income earned during the year under consideration. In this context, the Ld. AR relied on the following

THE DCIT, COCHIN vs. M/S.ASPINWALL & CO. LTD, COCHIN

In the result,the appeal of the Revenue in ITA No

ITA 133/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

254 ITR 377) (Delhi) 2) CIT vs. M/s. Walchand& Co. (Pvt.) Ltd. (65 ITR 381 (SC) 3) CIT vs. M/s. Edward Keventer (Private) Ltd. (115 ITR 149) (SC) 5.3 The Ld. AR submitted that disallowance computed u/s. 14A should not exceed the exempt income earned during the year under consideration. In this context, the Ld. AR relied on the following

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

ITA 61/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

254 ITR 377) (Delhi) 2) CIT vs. M/s. Walchand& Co. (Pvt.) Ltd. (65 ITR 381 (SC) 3) CIT vs. M/s. Edward Keventer (Private) Ltd. (115 ITR 149) (SC) 5.3 The Ld. AR submitted that disallowance computed u/s. 14A should not exceed the exempt income earned during the year under consideration. In this context, the Ld. AR relied on the following

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

ITA 60/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

254 ITR 377) (Delhi) 2) CIT vs. M/s. Walchand& Co. (Pvt.) Ltd. (65 ITR 381 (SC) 3) CIT vs. M/s. Edward Keventer (Private) Ltd. (115 ITR 149) (SC) 5.3 The Ld. AR submitted that disallowance computed u/s. 14A should not exceed the exempt income earned during the year under consideration. In this context, the Ld. AR relied on the following

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

transfer prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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

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 purposes are computed based on the books and not based on tax books and the prior period income was accounted in the books only in FY 2009-10 and hence, must be considered in this year. According to the Ld. AR, the Company had disclosed the said prior period income in the Form 3CEB

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 purposes are computed based on the books and not based on tax books and the prior period income was accounted in the books only in FY 2009-10 and hence, must be considered in this year. According to the Ld. AR, the Company had disclosed the said prior period income in the Form 3CEB