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120 results for “transfer pricing”+ Section 81clear

Sorted by relevance

Delhi1,603Mumbai1,526Bangalore592Karnataka307Ahmedabad289Chennai246Hyderabad220Kolkata209Surat191Jaipur190Chandigarh142Indore137Pune132Cochin120Visakhapatnam57Calcutta56Raipur36Cuttack34Lucknow28Rajkot25SC22Amritsar21Jodhpur18Telangana16Nagpur15Guwahati12Dehradun11Agra10Rajasthan4Jabalpur4Panaji3Allahabad2Ranchi2Orissa2Varanasi1MADAN B. LOKUR S.A. BOBDE1Kerala1Andhra Pradesh1A.K. SIKRI ROHINTON FALI NARIMAN1

Key Topics

Section 25094Addition to Income33Section 10(37)24Section 153A21Section 143(3)18Section 92C15Section 13214Capital Gains12Section 2(24)(vi)

APOLLO TYRES LTD.,COCHIN vs. DCIT CORPORATE CIR 1(1), KOCHI

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

ITA 679/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Sept 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, 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: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 154Section 35Section 92C

81,413 4 Apollo Tyres Ltd. 7. Being aggrieved by the final assessment order the appellant is in appeal before this Tribunal in the present appeal raising the following grounds: - “1. The assessment order passed u/s 143(3) r.w.s., 144C(13) & 144B of the Income-tax Act, 1961 ('the Act') dated 20th June, 2024, by the Assessment Unit, Income

Showing 1–20 of 120 · Page 1 of 6

8
Section 488
Disallowance8
Survey u/s 133A7

THE ACIT, CIRCLE-1, KOLLAM vs. M/S.OLAM AGRO INDIA P. LTD, KOLLAM

In the result, the appeal filed by the Revenue is dismissed

ITA 560/COCH/2019[2013-14]Status: DisposedITAT Cochin02 Mar 2020AY 2013-14

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year: 2013-14

Section 143(3)Section 144Section 144CSection 156Section 92C

transfer pricing adjustments. 4. Against this, the Revenue is in appeal before us. The Revenue has relied on the grounds raised. I.T.A. No.560/Coch/2019 5. The Ld. AR submitted that the assessment was bad in law as no draft assessment order was given to the assessee in violation of provisions contained in section 144C of the I.T. Act and, therefore

THE ACIT, CIRCLE-1, KOLLAM vs. M/S.OLAM AGRO INDIA P. LTD, KOLLAM

In the result, the appeal filed by the Revenue is dismissed

ITA 518/COCH/2019[2014-15]Status: DisposedITAT Cochin14 Jan 2020AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Mritunjaya Sharma, Sr.DRFor Respondent: Smt.Surabhi Agarwal &
Section 143(2)Section 143(3)Section 144CSection 92BSection 92C

transfer pricing adjustment made by the TPO. 4. Aggrieved by the assessment order, the assessee filed an appeal to the first appellate authority. Before the first appellate authority it was contended that the assessee was not issued draft assessment order. Therefore, it was submitted that the assessee was denied an opportunity to approach the Dispute Resolution Panel

M/S.ALLIANZ CORNHILL INFORMATION SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, ground Nos

ITA 489/COCH/2016[2012-13]Status: DisposedITAT Cochin24 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S, AdvocateFor Respondent: Sri. Santhom Bose, CIT-DR
Section 143(2)Section 143(3)Section 144C(2)(b)Section 156Section 2Section 36(1)(va)Section 40

Transfer Pricing adjustment Rs. 62,81,151 2.2 On receipt of the draft assessment order, the assessee filed its objection u/s 144C(2)(b) of the I.T.Act before the Dispute Resolution Panel (DRP). The DRP vide its order dated ITA No.489/Coch/2016 & SA 60/Coch/2017. 3 M/s.Allianz Cornhill International Services Pvt.Ltd. 12.08.2016, disposed off the objections of the assessee. The direction

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

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

THE ITO, WARD-2, THODUPUZHA, THODUPUZHA vs. SRI.MARTIN JOHNY, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 354/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

SRI.ESSA ISMAIL SAIT,ERNAKULAM vs. THE ACIT,CIR-2(1),, ERNAKULAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 605/COCH/2005[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THEACIT, CIR-1(1),EKM, ERNAKULAM vs. SRI.E.M.JOHNY, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 453/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ITO, WD-2, THODUPUZHA, THODUPUZHA vs. SRI.E.J.SONY, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 355/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ACIT, CIRCLE-1(1), ERNAKULAM, ERNAKULAM vs. SRI.MATHAI XAVIER, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 451/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ACIT, CIRCLE-1(1), ERNAKULAM, ERNAKULAM vs. SRI.E.M.PAUL, EDAKATTUKUDIYIL, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 449/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ACIT, CIR-1(1), ERNAKULAM, ERNAKULAM vs. SRI.JOSE MATHEW, M/S.E.V.MTHAI & SONS, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 450/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ITO, WD-2, THODUPUZHA, THODUPUZHA vs. SRI.TOMY MATHEW PARTNER OF MATHAI SONS, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 419/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate
Section 143Section 92C

section 92CA(1) of the Act, to the Transfer Pricing Officer (TPO) for the purpose of determination of ALP in respect of the above international transaction. 4 The TPO vide order dated 09/10/2023 passed u/s. 92CA(3), suggested the TP adjustment in respect of software development agreement of Rs. 12,84,50,000/- and also interest on delayed receivables

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 30/COCH/2019[2007-08]Status: DisposedITAT Cochin30 Sept 2019AY 2007-08

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

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas

THE DCIT, CEN-CIRCLE, KOTTAYAM vs. SRI.JOSE THOMAS, ADOOR

In the result, the appeals of the assesses in ITA no

ITA 55/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 31/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 308/COCH/2019[2008-09]Status: DisposedITAT Cochin30 Sept 2019AY 2008-09

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

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas