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143 results for “transfer pricing”+ Section 83clear

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Key Topics

Section 25094 Addition to Income36 Section 143(3)18 Section 92C9 Capital Gains9 Section 2638 Section 2(24)(vi)8 Section 488 Section 153A6

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

83,13,172/- with its Associated Enterprises. The case of the Assessee was referred to the Transfer Pricing Officer (TPO) under Section

Showing 1–20 of 143 · Page 1 of 8

...

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 141/COCH/2021[2000-2001]Status: DisposedITAT Cochin17 Jan 2024AY 2000-2001

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 143(1)Section 148(1)Section 271(1)(c)Section 274Section 80Section 801A(9)Section 80HSection 80I

section 801A(9); iv. Deduction under sec. 80HHC was re-worked; v. Addition on account of under-pricing of sales of cashew kernels to sister concerns in the course of exports (Rs. 3,21,15,027/-) The foregoing constitute the primary, undisputed facts of the case. 3.1 In the penalty proceedings, which were though considered only in respect of addition

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

transfers to them. (6) In the event of an addition alleging under pricing to sister concerns, corresponding addition in the purchase cost of the latter ought to have been recognized and benefit given in their assessment. Thus, the whole exercise becomes revenue neutral(2010) 236 CTR (SC) 113. Supreme Court decision was misconstrued. (7) Having accepted the trading results filed

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

section 92B of the I.T.Act with its Associated Enterprises, the matter was referred to the Transfer Pricing Officer (TPO). The TPO vide its order dated 30.10.2017 u/s 92CA(3) of the I.T.Act, proposed transfer pricing adjustment of Rs.7,32,83

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

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.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