BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

498 results for “transfer pricing”+ Section 192clear

Sorted by relevance

Delhi498Mumbai461Karnataka257Bangalore195Chennai104Jaipur73Kolkata71Ahmedabad62Hyderabad59Calcutta50Cochin48Chandigarh46Lucknow28Pune25Raipur21Indore17Guwahati16Jodhpur11Surat10Amritsar10Rajkot9Nagpur9Cuttack7SC7Telangana6Kerala5Allahabad4Rajasthan4Varanasi4Visakhapatnam3Andhra Pradesh1Orissa1

Key Topics

Section 143(3)64Addition to Income47Section 4034Section 143(2)32Section 92C31Section 153C29Transfer Pricing26Disallowance25Deduction23

(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

LIUGONG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed, as indicated above

ITA 1482/DEL/2015[2010-11]Status: DisposedITAT Delhi28 Jun 2016AY 2010-11

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

For Appellant: Sh. Manoj Pardasani, CAFor Respondent: Sh. Amrendra Kumar, CIT/DR
Section 143(3)

Showing 1–20 of 498 · Page 1 of 25

...
Section 14720
Section 194H20
Section 143(1)15
Section 144C(5)

Section I4A.” 15. Now, we first take up the transfer pricing issue. The first ground of appeal is against action of the lower authorities disregarding and ignoring comparable uncontrolled price submitted for international transactions pertaining to purchase of machinery of Rs.40,55,59,818/-. 18 ITA No.1482/Del./2015 16. The brief facts of this issue are that for the purpose

JAS FORWARDING WORLDWIDE PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

ITA 1687/DEL/2016[2011-12]Status: DisposedITAT Delhi26 Jul 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Salil Kapoor advocateFor Respondent: Shri M. Barnwal, Sr. DR
Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 40Section 92CSection 92C(2)

192 undertaken by the Learned Deputy Commissioner of Income-Tax, Circle 13(1), New Delhi ("the Ld. AO") [confirming additions by the Learned Additional Commissioner of Income-tax, Transfer Pricing Officer - 2(2) ("the Ld. TPO")] vide final assessment order dated January 30, 2016 passed under Section

JAS FORWARDING WORLDWIDE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

ITA 2484/DEL/2014[2009-10]Status: DisposedITAT Delhi26 Jul 2021AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Salil Kapoor advocateFor Respondent: Shri Surendra Pal [CIT] – DR
Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 40Section 92CSection 92C(2)

192 undertaken by the Learned Deputy Commissioner of Income-Tax, Circle 13(1), New Delhi ("the Ld. AO") [confirming additions by the Learned Additional Commissioner of Income-tax, Transfer Pricing Officer - 2(2) ("the Ld. TPO")] vide final assessment order dated January 30, 2016 passed under Section

STERIA (INDIA) LTD.,NOIDA vs. ADDL. CIT, SPL. RANGE- 8 , NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 5745/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Sept 2020AY 2014-15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR
Section 143Section 143(3)Section 144CSection 92C

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

M/S STERIA NDIA LTD.,,NOIDA vs. ADDL CIT, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 741/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Sept 2020AY 2012-13

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR
Section 143Section 143(3)Section 144CSection 92C

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

STERIA INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAQL RANGE-8, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

ITA 3992/DEL/2017[2013-14]Status: DisposedITAT Delhi28 Sept 2020AY 2013-14

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Sh. Anupam Kant Garg, CIT DR
Section 143Section 143(3)Section 144CSection 92C

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

KAPLAN INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

The appeal of the assessee is allowed with above directions

ITA 1022/DEL/2017[2012-13]Status: DisposedITAT Delhi10 May 2019AY 2012-13

Bench: Shri H. S. Sidhu & Shri Prashant Maharishikaplan India Pvt. Ltd, Vs. Ito, 226, Tribhuvan Complex, Ward-14(2), Ishwar Nagar, Friends Colony New Delhi (West),New Delhi Pan: Aaics9919F (Appellant) (Respondent) Kaplan India Pvt. Ltd, Vs. Addl. Cit, 226, Tribhuvan Complex, Special Range-5, Ishwar Nagar, Friends Colony New Delhi (West),New Delhi Pan: Aaics9919F (Appellant) (Respondent)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Sandeep Kr. Mishra, Sr. DR
Section 10Section 115JSection 143Section 144CSection 271Section 92C

transfer pricing officer however the learned dispute resolution panel has held that it is a high-end KPO. Admittedly there is no challenge to the functional profile stated by the learned dispute resolution panel. Admittedly the coordinate bench in B C Management Services (P) Ltd vs Deputy Commissioner Of Income Tax (2017) 83 taxmann.com 346 (Delhi) (Tribunal) dated 25/05/2017

A.T. KEARNEY INDIA PVT. LTD. (INDIA BRANCH OFFICE),GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee stands allowed in

ITA 2623/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Jun 2019AY 2010-11

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastavaassessment Year: 2010-11 A.T. Kearney India Pvt. Ltd. Acit, (India Branch Office), Circle 1(1), 6Th Floor, Tower D, New Delhi. Vs Global Business Park, Gurgaon-122002 (Pan: Aadca1436G) Appellant Respondent Assessee By: Shri Himanshu Sinha, Adv. Ms Vrinda Tulsiyan, Adv. Department By: Shri H.K. Choudhary, Cit Dr Ms Saweta Nakra, Sr. Dr Date Of Hearing : 14.06.2019 Date Of Pronouncement : 21.06.2019

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri H.K. Choudhary, CIT DR
Section 10ASection 143(1)Section 143(3)Section 144CSection 92C

192 iii) PCIT vs. Lionbridge Technologies Pvt. Ltd. of Hon’ble Bombay High Court reported in 86 taxmann.com 101 iv) ITO vs. Cerner Healthcare Solutions Pvt. Ltd. of the Bangalore Tribunal 83 taxmann.com 62 ITA 2623/Del/2015 Assessment year 2010-11 3.4 The ld. AR further argued that the voluntary transfer pricing adjustment made by the assessee will essentially have

M/S GEODIS OVERSEAS PVT. LTD.,,GURGAON vs. DCIT,, NEW DELHI

In the result, both the appeals are partly allowed for statistical purposes

ITA 3196/DEL/2017[2004-05]Status: DisposedITAT Delhi13 Aug 2025AY 2004-05

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv. & ShriFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 250Section 92C

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

DR. BHIM RAO AMBEDKAR MAHASANG HARYANA,FARIDABAD vs. CIT (EXEMPTIONS), CHANDIGARH/FARIDABAD

In the result, both the appeals are partly allowed for statistical purposes

ITA 3196/DEL/2023[NA]Status: DisposedITAT Delhi08 Apr 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv. & ShriFor Respondent: Ms. Neeju Gupta, Sr. DR
Section 250Section 92C

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

SUMITOMO CORPORATION INDIA PVT. LTD,NEW DELHI vs. NEAC, NEW DELHI

Accordingly, ITA number 508/del/2021 filed by the assessee for assessment year 2016 – 17 is partly allowed

ITA 507/DEL/2021[2015-16]Status: DisposedITAT Delhi24 Nov 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Himanshu Sinha, Adv.; &For Respondent: Shri Shashi Bhusan Shukla
Section 143(3)Section 144Section 144BSection 92CSection 92C(3)

192,42,60,698 5 between revised operating income and the arm’s-length income (step 3-step 4) Computed the proportion of 1.64% 6 international transactions (i.e. commission earned from associated enterprise) to the revised operating income (₹ 210,968,199/ ₹ 12,842,920,639 Calculate the transfer pricing 3,16,09,462 7 adjustment by restricting the difference

SUMITOMO CORPORATION INDIA PVT. LTD,NEW DELHI vs. NEAC, NEW DELHI

Accordingly, ITA number 508/del/2021 filed by the assessee for assessment year 2016 – 17 is partly allowed

ITA 508/DEL/2021[2016-17]Status: DisposedITAT Delhi24 Nov 2021AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Himanshu Sinha, Adv.; &For Respondent: Shri Shashi Bhusan Shukla
Section 143(3)Section 144Section 144BSection 92CSection 92C(3)

192,42,60,698 5 between revised operating income and the arm’s-length income (step 3-step 4) Computed the proportion of 1.64% 6 international transactions (i.e. commission earned from associated enterprise) to the revised operating income (₹ 210,968,199/ ₹ 12,842,920,639 Calculate the transfer pricing 3,16,09,462 7 adjustment by restricting the difference

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4518/DEL/2016[2011-12]Status: DisposedITAT Delhi03 Dec 2018AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

PEPSI FOODS PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 2511/DEL/2013[2008-09]Status: DisposedITAT Delhi03 Dec 2018AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S. PEPSI FOODS LIMITED,GURGAON vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 1044/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Dec 2018AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE- 7, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 6582/DEL/2017[2013-14]Status: DisposedITAT Delhi03 Dec 2018AY 2013-14

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4517/DEL/2016[2010-11]Status: DisposedITAT Delhi03 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

ITA 4516/DEL/2016[2010-11]Status: DisposedITAT Delhi03 Dec 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Respondent: Mr. H.K. Chaudhary, CIT-DR
Section 115JSection 145ASection 271(1)(c)

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 3327/DEL/2018[2013-14]Status: HeardITAT Delhi02 Sept 2019AY 2013-14

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

section 133A of the Act has no legal sanctity in the eyes of law and cannot be the basis for drawing any adverse inference against the assessee. Reliance in this regard is placed on the following decisions: i. CIT vs. S. Khader Khan Son : 210 Taxman 248 (SC) ii. Paul Mathews and Sons