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7 results for “transfer pricing”+ Section 92(3)clear

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Key Topics

Section 54B7Section 16Section 92D6Transfer Pricing6Addition to Income6Comparables/TP6

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

ITA 7334/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

ITA 7477/DEL/2017[2013-14]Status: DisposedITAT Dehradun
28 Apr 2025
AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

ITA 7848/DEL/2017[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 417/DEL/2018[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

ITA 5647/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 5696/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

ITA 149/DDN/2025[2106-2017]Status: DisposedITAT Dehradun14 Jan 2026AY 2106-2017

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Salil Aggarwal, Sr. Adv. &For Respondent: Sh. A. S. Rana, Sr. DR
Section 133(6)Section 143(3)Section 54BSection 54E

price at which the land was sold and whether the owner would have ever sold the land valuing it as a property yielding agricultural produce on the basis of its yield? At the risk of repetition, we may mention that not all of these factors would be present or absent in any case and that in each case