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73 results for “transfer pricing”+ Section 27clear

Sorted by relevance

Delhi1,506Mumbai1,478Hyderabad334Chennai324Bangalore271Ahmedabad203Jaipur175Kolkata135Chandigarh131Indore110Pune76Cochin73Rajkot57Surat50Visakhapatnam39Raipur38Nagpur34Cuttack28Amritsar27Agra22Lucknow20Guwahati19Dehradun17Jodhpur7Varanasi6Allahabad5Ranchi3Panaji1

Key Topics

Section 250114Disallowance8Section 143(3)7Section 40A(2)(b)6Section 406Section 92C6Addition to Income6Reassessment6Section 12A3

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

Section 92B of the Act. We also reject the contention of the Assessee that continuing debit balance of short term advances did not constitute an ‘International Transaction’. Therefore, Ground No. 4.1 raised by the Assessee is dismissed. 5.3. During the assessment proceedings the TPO noted that the Assessee was providing loans and advances to its AEs and was not charging

Showing 1–20 of 73 · Page 1 of 4

Section 113
Section 2(15)3
Transfer Pricing3

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes

ITA 562/COCH/2022[2017-2018]Status: DisposedITAT Cochin21 Oct 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 144C(3)Section 92C(3)

section 234B and 234C of the Act The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the appeal.” 3. At the outset, we note that the learned AR for the assessee before us submitted that issue raised by the assessee in ground

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

THE DCIT,CEN-CIRCLE,, THRISSUR vs. SRI.T.G. CHANDRAKUMAR, THRISSUR

In the result, the Appeal by the Revenue is allowed on the aforesaid terms

ITA 67/COCH/2018[2008-09]Status: DisposedITAT Cochin03 Apr 2023AY 2008-09

Bench: Shri Sanjay Arora (Accountant Member), Shri Sandeep Gosain (Judicial Member)

For Appellant: Smt. J.M. Jamuna Devi, Sr. DRFor Respondent: Shri C.B.M. Warrier, FCA
Section 132Section 153CSection 268A

section (3) thereof, would have no bearing on the merits of the case. The decision by the first appellate authority for that year, as for the current year, cannot bind this Tribunal, so that the matter cannot be regarded as covered, and would require being adjudicated by it on merits. The same would though be relevant and taken into account

GOOD HOMES PVT LTD,KOCHI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 884/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter ‘the Act’) dated 18.3.2015 and 29.3.2014 for assessment year (AY) 2007-2008, respectively. The background facts of both the cases being same, these are heard together, and are being disposed of pera common, consolidated order for the sake of convenience. ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit

AJIT ASSOCIATES PRIVATE LIMITED,ERNAKULAM vs. JCIT, CORPORATE RANGE - 1, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 870/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter ‘the Act’) dated 18.3.2015 and 29.3.2014 for assessment year (AY) 2007-2008, respectively. The background facts of both the cases being same, these are heard together, and are being disposed of pera common, consolidated order for the sake of convenience. ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally

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

27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur and ABC Sales Corporation in Taliparamba, a discrepancy in stock was found. The difference was observed between the stock recorded in the accounting software and the actual physical stock. The details of the stock difference are as follows: Showroom Actual as per Excel As per Tally