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69 results for “transfer pricing”+ Section 55(2)(a)clear

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Key Topics

Section 250114Section 143(3)20Addition to Income7Section 92C5Section 1325Section 153A5Section 153C5Section 12A3Section 113

APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

Section 92C(3) of the Act supported the contention of the Assessee that the TP documentation of the Assessee was rejected without appreciating the documents/submissions filed by the Assessee. 6.1. It was submitted that segmental information was submitted before the TPO alongwith Response, dated 20/09/2023, whereby it was explained/clarified by the Assessee as under: (a) The basis of segmenting each

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

Showing 1–20 of 69 · Page 1 of 4

Charitable Trust3
Exemption3
Comparables/TP3

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 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 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

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

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

M/S.JOY ALUKKAS INDIA P. LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 38/COCH/2017[2012-13]Status: DisposedITAT Cochin08 Sept 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

55,305/- e) Disallowance of interest u/s. 36(1)(viii) of Rs. 1,39,04,056/- f) Disallowance of advertisement expenses of Rs. 1,05,59,467/-. 8. On receipt of draft assessment order, the appellant-company had filed several objections before the Dispute Resolution Panel-2, Bangalore (DRP). The DRP issued directions confirming the addition of TP adjustments

M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

55,305/- e) Disallowance of interest u/s. 36(1)(viii) of Rs. 1,39,04,056/- f) Disallowance of advertisement expenses of Rs. 1,05,59,467/-. 8. On receipt of draft assessment order, the appellant-company had filed several objections before the Dispute Resolution Panel-2, Bangalore (DRP). The DRP issued directions confirming the addition of TP adjustments

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

55,867 9 Payment of royalty 1,49,06,399 10 Receipt of research and testing services 12,81,14,109 11 Receipt of corporate marketing services 391,40,800 12 Provision of corporate purchase 23,08,219 services 13 Provision of corporate information 2,32,10,5456 technology services 14 Investment in equity 50,02,98,250 15 Reimbursement

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 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,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

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

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

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

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

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

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

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

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