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68 results for “transfer pricing”+ Section 10(22)clear

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Key Topics

Section 801A63Addition to Income41Section 143(3)36Section 26325Section 142(1)22Exemption22Deduction21Disallowance20Section 10(38)18

KSSIIPL VEL JV,PURI vs. ACIT CIRCLE-5(1), BHUBANESWAR

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

ITA 91/CTK/2023[2014-15]Status: DisposedITAT Cuttack29 Aug 2024AY 2014-15
For Appellant: Ms. Pooja Dhalwani, CAFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 143(2)Section 40A(2)Section 92C

section 92F(iii) and reading the said provision along with Rule 10B(l)(e) of the Rules, the Tribunal held that the net profit margin of the Enterprise which is in India, has to be determined by applying the Transfer Pricing Regulations. The Tribunal was largely guided by the decision of the Mumbai Tribunal in Aurionpro Solutions Limited, wherein

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

Showing 1–20 of 68 · Page 1 of 4

Capital Gains16
Long Term Capital Gains16
Section 14715
ITA 208/CTK/2024[2003-04]Status: DisposedITAT Cuttack25 Sept 2024AY 2003-04
Section 11Section 11(1)(a)Section 12ASection 260Section 263

22 ITA Nos.208-210/CTK/2024 Explanation 1.—For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,— 3. an order passed on or before or after the 1st day of June, " 1988 by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] shall include— " 3. an order of assessment made

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

ITA 209/CTK/2024[2004-05]Status: DisposedITAT Cuttack25 Sept 2024AY 2004-05
Section 11Section 11(1)(a)Section 12ASection 260Section 263

22 ITA Nos.208-210/CTK/2024 Explanation 1.—For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,— 3. an order passed on or before or after the 1st day of June, " 1988 by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] shall include— " 3. an order of assessment made

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

ITA 210/CTK/2024[2005-06]Status: DisposedITAT Cuttack25 Sept 2024AY 2005-06
Section 11Section 11(1)(a)Section 12ASection 260Section 263

22 ITA Nos.208-210/CTK/2024 Explanation 1.—For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,— 3. an order passed on or before or after the 1st day of June, " 1988 by the Assessing Officer [or the Transfer Pricing Officer, as the case may be,] shall include— " 3. an order of assessment made

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 44/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. SITANSU SEKHAR MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 38/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. ANUPAMA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 40/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 42/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 45/CTK/2020[2015-16]Status: DisposedITAT Cuttack21 Dec 2021AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. ANUPAMA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 41/CTK/2020[2015-16]Status: DisposedITAT Cuttack21 Dec 2021AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 43/CTK/2020[2015-16]Status: DisposedITAT Cuttack21 Dec 2021AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. AMRUTA PREETAM MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 46/CTK/2020[2014-15]Status: DisposedITAT Cuttack17 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. KISHORE KUMAR MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 48/CTK/2020[2014-15]Status: DisposedITAT Cuttack17 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. MAMATA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 47/CTK/2020[2014-15]Status: DisposedITAT Cuttack17 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD , BHADRAK vs. PARBATI MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 49/CTK/2020[2014-15]Status: DisposedITAT Cuttack17 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

ITO, BHADRAK WARD, BHADRAK vs. SMT. KUNTALA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 50/CTK/2020[2014-15]Status: DisposedITAT Cuttack17 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

22,41,000 15.000 37.25.000 After deducting the proportionate cost price of Rs.30,000/- and other expenses including STT the Net Long Term Capital Gains was computed at Rs.36,76,819/- and the same was claimed an exempt u/s. 10(38). The order of the Hon'ble Income Tax Appellate Tribunal, "A" Bench, Kolkata in the cases of Shri Manish

SATISH KUMAR GARG,ROURKELA vs. ITO WARD-5, ROURKELA

In the result, appeal of assessee stands allowed

ITA 223/CTK/2023[2014-15]Status: DisposedITAT Cuttack25 Sept 2024AY 2014-15

Bench: Before Shri George Mathanmember Assessment Year : 2014-15 Satish Satish Kumar Kumar Vs. Income Tax Officer, Ward-5, Income Tax Officer, Ward Garg,Gurudwara Road, Near Garg,Gurudwara Road, Near Aayakar Bhavan, Uditnagar, Aayakar Bhavan, Uditnagar, Gurudwara, Rourkela Gurudwara, Rourkela Rourkela Pan/Gir No. . (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty, Adv : Shri P.R.Mohanty, Adv Revenue By : Shri S.C.Mohanty, Ld Sr Dr , Ld Sr Dr Date Of Hearing : 25/09/20 2024 Date Of Pronouncement : 25/09/2 2024 O R D E R This Is An Appeal Filed By The Revenue An Appeal Filed By The Revenue Against The Order Of The Ld Inst The Order Of The Ld Cit(A), Cit(A), Nfac, Nfac, Delhi Delhi Dated 26.12.2022 In Appeal No.Cit(A),Sambalpur/10380/2016 Sambalpur/10380/2016-17 For The Assessment Year 2014 Assessment Year 2014-15. 2. Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. S.C.Mohanty, Ld Sr Dr Appeared For The Revenue.

For Appellant: Shri P.R.Mohanty, AdvFor Respondent: Shri S.C.Mohanty, ld Sr DR
Section 10(38)

22 24940.5 31.1.14 20 18117.84 3.2.14 43 37063.63 4.2.14 11 9135.07 5.2.14 50 39523.07 6.2.14 20 15715.33 7.2.14 26 20158.09 11.2.14 9 6795.95 24.2.14 20 10759.04 1000 1107865.24 Long term profit -880244.21 Total: 1107866 4. It was the submission that the assessee had purchased shares for Rs.2,27,627.12 and same was sold at Rs.11,07,865.24 thereby generating long

PRAKASH AGARWAL,ROURKELA vs. INCOME TAX OFFICER, KEONJHAR

In the result, appeal of assessee stands allowed

ITA 223/CTK/2024[2017-18]Status: DisposedITAT Cuttack05 Aug 2024AY 2017-18

Bench: Before Shri George Mathanmember Assessment Year : 2014-15 Satish Satish Kumar Kumar Vs. Income Tax Officer, Ward-5, Income Tax Officer, Ward Garg,Gurudwara Road, Near Garg,Gurudwara Road, Near Aayakar Bhavan, Uditnagar, Aayakar Bhavan, Uditnagar, Gurudwara, Rourkela Gurudwara, Rourkela Rourkela Pan/Gir No. . (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty, Adv : Shri P.R.Mohanty, Adv Revenue By : Shri S.C.Mohanty, Ld Sr Dr , Ld Sr Dr Date Of Hearing : 25/09/20 2024 Date Of Pronouncement : 25/09/2 2024 O R D E R This Is An Appeal Filed By The Revenue An Appeal Filed By The Revenue Against The Order Of The Ld Inst The Order Of The Ld Cit(A), Cit(A), Nfac, Nfac, Delhi Delhi Dated 26.12.2024 In Appeal No.Cit(A),Sambalpur/10380/2016 Sambalpur/10380/2016-17 For The Assessment Year 2014 Assessment Year 2014-15. 2. Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri Shri P.R.Mohanty, Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. S.C.Mohanty, Ld Sr Dr Appeared For The Revenue.

For Appellant: Shri P.R.Mohanty, AdvFor Respondent: Shri S.C.Mohanty, ld Sr DR
Section 10(38)

22 24940.5 31.1.14 20 18117.84 3.2.14 43 37063.63 4.2.14 11 9135.07 5.2.14 50 39523.07 6.2.14 20 15715.33 7.2.14 26 20158.09 11.2.14 9 6795.95 24.2.14 20 10759.04 1000 1107865.24 Long term profit -880244.21 Total: 1107866 4. It was the submission that the assessee had purchased shares for Rs.2,27,627.12 and same was sold at Rs.11,07,865.24 thereby generating long

DCIT, CIRCLE-1(1), BHUBANESWAR, BHUBANESWAR vs. M/S. PARADEEP PHOSPHATES LIMITED, BHUBANESWAR

In the result, appeal filed by the revenue is dismissed and that of

ITA 289/CTK/2014[2010-11]Status: DisposedITAT Cuttack04 Aug 2017AY 2010-11

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2010-2011

For Appellant: Shri B.K.MohapatraFor Respondent: Shri Kunal Singh, CIT DR
Section 195Section 195(1)Section 195(2)Section 197Section 263Section 40Section 92

Transfer Pricing (TP) assessment for the AY 2010-11 has been completed on 30.01.2014 with "NIL Adjustment" after going through in detail, the transactions of imports from various parties being associated enterprises within the meaning of Section 92 (C) of the Income Tax Act, 1961. Copy of the aforesaid Order is enclosed and marked as Annexure-1 for your kind

RASHI AGRAWAL,CUTTACKI vs. INCOME TAX OFFICER, CUTTACK

In the result, appeal of the assessee allowed

ITA 56/CTK/2023[2014-15]Status: HeardITAT Cuttack04 May 2023AY 2014-15
For Appellant: Shri Keshav Dubey, CAFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 10(38)

price as it was the appellant who had traded in the shares of the this company which resulted into claim of long term capital gains which is exempt under section 10(38). Once the assessee was made aware of the result of the investigation which proved that trading of shares leading to long term capital gains was not genuine