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350 results for “transfer pricing”+ Section 191clear

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Key Topics

Section 143(3)74Addition to Income46Section 14730Disallowance26Section 92C25Transfer Pricing25Deduction25Section 14A23Section 143(2)22

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

M/S. HONDA SIEL POWER PRODUCTS LTD.,GAUTAM BUDH NAGAR vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

ITA 551/DEL/2014[2009-10]Status: DisposedITAT Delhi13 Apr 2016AY 2009-10

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: S/Sh. Neeraj Jain, AdvFor Respondent: Sh. Armendra Kumar, CIT/ DR
Section 143(3)

Showing 1–20 of 350 · Page 1 of 18

...
Section 14821
Section 115J20
Section 153C20
Section 144C
Section 2
Section 92B

section 40(a)(i) are directed to be deleted. Accordingly, these grounds of appeal stand allowed. In view of this decision of co-ordinate Bench in the case of assessee, the advance ruling relied on by the ld. DR does not help the revenue, as the said ruling is binding on that applicant and not upon the Tribunal u/s. 245S

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

ITA/52/2023HC Delhi02 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

transfer pricing adjustment as proposed by the TPO and disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. objections before the DRP, even though the Respondent

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

ITA/993/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

transfer pricing adjustment as proposed by the TPO and disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. objections before the DRP, even though the Respondent

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

ITA/995/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

transfer pricing adjustment as proposed by the TPO and disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. objections before the DRP, even though the Respondent

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

In the result, the appeal of the revenue in ITA No

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

In the result, the appeal of the revenue in ITA No

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

In the result, the appeal of the revenue in ITA No

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the revenue in ITA No

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,UTTAR PRADESH vs. ACIT, NOIDA

In the result, the appeal of the assessee in ITA No

ITA 6253/DEL/2012[2008-09]Status: DisposedITAT Delhi14 Jan 2019AY 2008-09

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2008-09] L.G. Electronics India Pvt. Ltd Vs. The Asstt. C.I.T A-27, Mohan Co-Operative Industrial Circle - 3 Estate, Mathura Road Noida [U.P] New Delhi Pan : Aaacl 1745 Q [Appellant] [Respondent] Date Of Hearing : 13.12.2018 Date Of Pronouncement : 14.01.2019

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 10BSection 143(3)Section 144C(5)Section 80J

Transfer Pricing adjustment on account of payment of overseas marketing related services of Rs 1,30,08,500/-. 60. Facts on record show that during the year under consideration, the assessee requested its associated enterprises to carry out market survey for its overseas operations. Actual costs of carrying out such survey, such as, personnel costs and other direct expenses, were

THE COMMISSIONER OF INCOME TAX vs. M/S NALWA INVESTMENT LTD.

Appeals are allowed

ITA/822/2005HC Delhi07 Aug 2020

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE SANJEEV NARULA

Section 260ASection 391Section 47

price of shares of JSL on 23rd December, 1996 [record date under the scheme of amalgamation] and even ITA 822/2005 & connected matters Page 9 of 37 if the value of Rs.76 per share is adopted, the same will result in business loss instead of business profit as worked out by the AO. 10. Mr. Vohra strenuously urged that there

COMMISSIONER OF INCOME TAX DEL vs. M/S MANSAROVAR INVESTMENTS LTD

Appeals are allowed

ITA/961/2005HC Delhi07 Aug 2020

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE SANJEEV NARULA

Section 260ASection 391Section 47

price of shares of JSL on 23rd December, 1996 [record date under the scheme of amalgamation] and even ITA 822/2005 & connected matters Page 9 of 37 if the value of Rs.76 per share is adopted, the same will result in business loss instead of business profit as worked out by the AO. 10. Mr. Vohra strenuously urged that there

COMMISSIONER OF INCOME TAX DEL vs. M/S MANSAROVAR INVESTMENTS LTD

Appeals are allowed

ITA - 961 / 2005HC Delhi07 Aug 2020
Section 260ASection 391Section 47

price of shares of JSL on 23rd December, 1996 [record date under the scheme of amalgamation] and even 2020:DHC:2490-DB ITA 822/2005 & connected matters Page 9 of 37 if the value of Rs.76 per share is adopted, the same will result in business loss instead of business profit as worked out by the AO. 10. Mr. Vohra strenuously

COMMISSIONER OF INCOME TAX DEL vs. M/S M/S JINDAL EQUIPMENT LEASI

Appeals are allowed

ITA - 935 / 2005HC Delhi07 Aug 2020
Section 260ASection 391Section 47

price of shares of JSL on 23rd December, 1996 [record date under the scheme of amalgamation] and even 2020:DHC:2490-DB ITA 822/2005 & connected matters Page 9 of 37 if the value of Rs.76 per share is adopted, the same will result in business loss instead of business profit as worked out by the AO. 10. Mr. Vohra strenuously

COMMISSIONER OF INCOME TAX DEL vs. M/S ABHUINANDAN INVESTMENTS LT

Appeals are allowed

ITA - 853 / 2005HC Delhi07 Aug 2020
Section 260ASection 391Section 47

price of shares of JSL on 23rd December, 1996 [record date under the scheme of amalgamation] and even 2020:DHC:2490-DB ITA 822/2005 & connected matters Page 9 of 37 if the value of Rs.76 per share is adopted, the same will result in business loss instead of business profit as worked out by the AO. 10. Mr. Vohra strenuously