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16 results for “transfer pricing”+ Section 44clear

Sorted by relevance

Mumbai1,144Delhi830Chennai224Hyderabad210Bangalore188Ahmedabad146Jaipur133Chandigarh126Kolkata111Cochin64Indore63Rajkot45Pune44Surat34Raipur31Visakhapatnam27Nagpur25Lucknow24Amritsar22Guwahati18Agra17Jodhpur16Cuttack16Dehradun6Varanasi5Panaji5Jabalpur2Ranchi1Patna1

Key Topics

Section 801A63Section 26312Section 26012Addition to Income12Deduction10Section 119Section 269S8Section 153A7Section 807

INDIAN METALS AND FERRO ALLOYS LTD,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANESWAR

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

Section 80IA of the Act. 36. As is apparent from Sub-clause (i) of Clause (a) of Rule 10B(1) of the Rules, it is necessary to determine the price charged or paid for the property or goods transferred or services provided in a comparable uncontrolled transaction. In the present case, the transaction relates to the sale of electricity

Section 194C7
Disallowance7
Penalty4

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

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

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

44,658 4,12,72,82,943 4,71,38,34,002 Finance and Misc Income(b) Total (a+b) 25,33,04,319 18,79,37,391 24,26,05,504 4,06,55,48,977 4,31,52,20,334 4,95,64,39,506 Less : 15% of gross receipts permitted to be accumulated

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

44,658 4,12,72,82,943 4,71,38,34,002 Finance and Misc Income(b) Total (a+b) 25,33,04,319 18,79,37,391 24,26,05,504 4,06,55,48,977 4,31,52,20,334 4,95,64,39,506 Less : 15% of gross receipts permitted to be accumulated

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

44,658 4,12,72,82,943 4,71,38,34,002 Finance and Misc Income(b) Total (a+b) 25,33,04,319 18,79,37,391 24,26,05,504 4,06,55,48,977 4,31,52,20,334 4,95,64,39,506 Less : 15% of gross receipts permitted to be accumulated

ITO, ANGUL WARD, ANGUL vs. NCC-SMASL-JRT(JV), ANGUL

ITA 39/CTK/2018[2013-14]Status: HeardITAT Cuttack25 Jul 2024AY 2013-14
For Appellant: Shri Salil Kapoor and Bibhu Jain, AdvsFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 40A(2)(b)

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

ITO, ANGUL WARD, , ANGUL vs. M/S. NCC SMASL JRT(JV),, ANGUL

ITA 99/CTK/2019[2014-15]Status: DisposedITAT Cuttack25 Jul 2024AY 2014-15
For Appellant: Shri Salil Kapoor and Bibhu Jain, AdvsFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 40A(2)(b)

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. DCIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 89/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

M/S. SHREE BAALAJI ENGICONS LIMITED,JHARSUGUDA vs. DEPUTY COMMISSIONER OF INCOME TAX ( CENTRAL CIRCLE-1(1), SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 296/CTK/2023[2013-14]Status: DisposedITAT Cuttack07 Jan 2025AY 2013-14

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

ASST. CIT, CENTRAL CIRCLE, SAMBALPUR, AAYAKAR BHAWAN, SAMBALPUR vs. SHREE BALAJI ENGICON LIMITED, BELPAHAR RS

In the result, appeals of the assesee in IT(SS)A No

ITA 320/CTK/2023[2011-12]Status: DisposedITAT Cuttack07 Jan 2025AY 2011-12

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. ACIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 88/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 13/CTK/2023[2018-19]Status: DisposedITAT Cuttack07 Jan 2025AY 2018-19

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 141/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 142/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

price in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

In the result, all the three appeals of the Revenue are dismissed

ITA 206/CTK/2022[2012-13]Status: DisposedITAT Cuttack18 Sept 2024AY 2012-13
Section 132Section 269SSection 271D

price and credited to the said fund were first liable to be used in adjusting the losses of the respondent society in the working year; thereafter in the repayment of initial loan from the Industrial Finance Corporation of India and then for redeeming the Government share and only in the event of any balance being left, it was liable

DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

In the result, all the three appeals of the Revenue are dismissed

ITA 205/CTK/2022[2009-10]Status: DisposedITAT Cuttack18 Sept 2024AY 2009-10
Section 132Section 269SSection 271D

price and credited to the said fund were first liable to be used in adjusting the losses of the respondent society in the working year; thereafter in the repayment of initial loan from the Industrial Finance Corporation of India and then for redeeming the Government share and only in the event of any balance being left, it was liable

SMT. PURNIMA DAS,BHUBANESWAR vs. PR. CIT-1,, BHUBANESWAR

ITA 95/CTK/2022[2017-18]Status: HeardITAT Cuttack16 Feb 2023AY 2017-18

Bench: S/Shri George Mathan & Arun Khodpiaassessment Year : 2017-18 Smt. Purnima Das, C/O. Vs. Pr. Cit, Bhubaneswar-1. Biswajit Das, At-9, Budha Nagar, Budheswari, Bhubaneswar. Pan/Gir No.Aazpd0112 B (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri M.K.Gautam, Cit Dr Date Of Hearing : 16/02/2023 Date Of Pronouncement : 16/02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit Passed U./S.263 Of The Act, Dated 12.3.2022 In Appeal No. Itba/Rev/F/Reev5/2021-22/10540634159(1) For The Assessment Year 2017-18. 2. Shri P.K.Mishra, Ld Ar Appeared For The Assessee Assisted By Ms.Sugyanee Kuanr & Ms. Simran Samal, Intern From Birla School Of Law (Bgu), Bhubaneswar & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue Assisted By Shri Dharmashoka Panda, Intern From Birla School Of Law (Bgu), Bhubaneswar. 3. It Was Submitted By Ld Ar That The Assessee Is An Individual, Who Is A Professor Of Mathematics At P.N.College, Khurda. The Assessee Had Filed Her Return Of Income For The Relevant Assessment Year On 5.8.2017

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 271D

44,000/- on 22.07.2010. The registration fee/stamp duty of Rs.3,07,194/- was paid on said purchase of land. It is not understood as to how the registration fee/stamp duty of Rs.10,74,394/- was claimed by the appellant in her computation of capital gains. ii.) The abovementioned land was sold to M/s. Shree Cement Ltd. for industrial purposes