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107 results for “transfer pricing”+ Section 96clear

Sorted by relevance

Mumbai1,468Delhi1,429Bangalore641Karnataka315Chennai308Ahmedabad291Kolkata259Hyderabad232Jaipur179Pune128Chandigarh117Cochin107Indore92Calcutta51Surat50Visakhapatnam44Raipur33Cuttack31Agra26Lucknow24Rajkot20SC19Telangana17Nagpur16Jodhpur11Amritsar5Rajasthan4Dehradun4Allahabad3Guwahati3Orissa2Kerala2Panaji2A.K. SIKRI ROHINTON FALI NARIMAN1D.K. JAIN JAGDISH SINGH KHEHAR1Andhra Pradesh1Patna1Punjab & Haryana1Ranchi1Varanasi1

Key Topics

Section 250108Addition to Income34Section 153A32Section 143(3)20Section 13218Section 143(2)12Section 2639Disallowance8Section 143(1)7

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

96,08,040/-. The return of income was selected for scrutiny through CASS. During the assessment proceedings, it was noticed from the audit report in Form 3CEB that the Assessee had entered into International Transactions amounting to INR.2,34,83,13,172/- with its Associated Enterprises. The case of the Assessee was referred to the Transfer Pricing Officer (TPO) under

Showing 1–20 of 107 · Page 1 of 6

Section 406
Reassessment4
Exemption4

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

96,832/- (as detailed in bellows paras) by re- determining the arm's length price of the transaction by not appreciating that the arm length price is duly computed by independent Chartered Accountant in TP Memorandum. 12.1 On the facts and in the circumstances of the case and in law, the Ld. AO /ld. TPO grossly erred in making transfer

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

ITA 171/COCH/2024[2018-2019]Status: DisposedITAT Cochin11 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Dijo Mathew, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(2)Section 270ASection 270A(1)Section 270A(2)Section 36(1)(viia)Section 40

section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or 96[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide and the assessee has disclosed

M/S.MALANKARA ORTHODOX SYRIAN CHURCH MEDICAL MISSION HOSPITAL,COCHIN vs. THE DY DIT (EXEMPTION), COCHIN

In the result, the appeal filed by the assessee is allowed

ITA 127/COCH/2016[2011-12]Status: DisposedITAT Cochin16 Mar 2017AY 2011-12

Bench: S/Shri Abraham P George, Am & George George K, Jm Malankara Orthodox Syrian Church Vs The Dy Director Of Income Tax Medical Mission Hospital (Exemption) Kolencherry 682 311 Kochi ( Appellant) (Respondent)

Section 11Section 11(4)Section 12ASection 143(3)Section 263Section 40A(7)Section 47A(7)

96,547/-. This amount was not disallowed either in the income tax return filed by the assessee or in the assessment order passed u/s 143(3) of the Act. The provision for gratuity is not an allowable deduction as per provisions of section 40A(7) of the I T Act. Therefore, the CIT has rightly disallowed the same

M/S.TRIO PROPERTY DEVELOPERS P. LTD,CALICUT vs. THE ACIT, CALICUT

In the result, the appeal of the assessee is allowed

ITA 235/COCH/2016[2006-07]Status: DisposedITAT Cochin07 Jun 2017AY 2006-07

Bench: S/Shri Abraham P. George, Am & George George K., Jm

Section 143(1)Section 148Section 263Section 53Section 53A

price for the constructed area of 71,444 sq. ft. which was to be delivered to the assessee, as per the agreement was Rs.975 per sq. ft. The Assessing Officer was of the opinion that assessee having handed over the possession of the land, there was a transfer within the meaning of 2(47) of the Act read with section

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 35/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

THE DCIT CEN-CIRCLE, KOTTAYAM vs. SMT.GRACY BABU, ADOOR P.O.

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

ITA 54/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 33/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

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

ITA 309/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

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

ITA 305/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

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

ITA 310/COCH/2019[2010-11]Status: DisposedITAT Cochin30 Sept 2019AY 2010-11

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 34/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

THE ACIT CEN-CIRCLE, KOTTAYAM vs. SMT.GRACY BABU, ADOOR P.O.

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

ITA 239/COCH/2019[2011-12]Status: DisposedITAT Cochin30 Sept 2019AY 2011-12

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

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

ITA 238/COCH/2019[2011-12]Status: DisposedITAT Cochin30 Sept 2019AY 2011-12

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

In the result, the appeals of the assessesin ITA no

ITA 29/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

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

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

ITA 306/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 210/COCH/2019[2011-12]Status: DisposedITAT Cochin30 Sept 2019AY 2011-12

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting