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644 results for “transfer pricing”+ Section 201(3)clear

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Key Topics

Section 143(3)57Addition to Income47Section 194H33Section 14731Deduction29Disallowance24Section 14822TDS22Transfer Pricing17Section 154

(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

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

ITA 196/DEL/2013[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

For Appellant: 1. Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amrendra Kumar, CIT, DR

Showing 1–20 of 644 · Page 1 of 33

...
16
Section 92C15
Section 133A15
Section 143Section 143(3)Section 92D

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

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

transfer pricing officer Page 17 of 95 included by the learned assessing officer in the assessment order, therefore ground number 2 along with all its sub grounds are allowed as directed above. 31. Now coming to ground number 3 of the appeal which is against the disallowance of management services fees

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

transfer pricing officer Page 17 of 95 included by the learned assessing officer in the assessment order, therefore ground number 2 along with all its sub grounds are allowed as directed above. 31. Now coming to ground number 3 of the appeal which is against the disallowance of management services fees

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

transfer pricing officer Page 17 of 95 included by the learned assessing officer in the assessment order, therefore ground number 2 along with all its sub grounds are allowed as directed above. 31. Now coming to ground number 3 of the appeal which is against the disallowance of management services fees

ETT LTD (FORMERLY KNOWN AS INDIAN EXPRESS MULTIMEDIA LTD),NEW DELHI vs. CIT, CENTRAL-II, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3341/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Mar 2019AY 2013-14

Bench: Sh. Amit Shukla & Sh. Anadee Nath Misshraassessment Year: 2013-14

Section 115Section 143Section 14ASection 153Section 263Section 80Section 80I

transfer pricing were applicable which has not been scrutinized by the Assessing Officer. 5. In response to the show cause notice assessee filed detailed submissions and documents placed on record before Assessing Officer on various dates, which is running into almost 200 pages, the copy of which has been placed in the paper book from pages 4 to 201 before

NOKIA INDIA SALES P.LTD,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE-6, , NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 7244/DEL/2017[2013-14]Status: DisposedITAT Delhi25 Oct 2021AY 2013-14

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7244/Del/2017 : Asstt. Year : 2012-13 Nokia India Sales Pvt. Ltd., Vs Addl. Cit, 807, New Delhi House, Special Range-6, Barakhamba Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaccn9141L Assessee By : Sh. Nageshwar Rao, Adv. Revenue By : Sh. Surenderpal, Cit Dr Date Of Hearing: 29.07.2021 Date Of Pronouncement: 25.10.2021

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Surenderpal, CIT DR
Section 133(6)Section 143(3)Section 194HSection 194JSection 40Section 9(1)(vii)

transfer pricing officer (“Ld. TPO”) erred in enhancing the income of the Appellant by Rs. 1,44,00,000/- by making a TP adjustment on account of AMP expenses incurred by the Appellant in the regular course of its business on the ground that it was excessive and should be compensated by the associated enterprises (“AE”). 5.1 That

M/S. BHARTI AIRTEL LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result appeal of the assessee with respect to ground No

ITA 5816/DEL/2012[2008-09]Status: DisposedITAT Delhi24 Oct 2016AY 2008-09

Bench: Shri I.C.Sudhir & Shri Prashant Maharishibharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vasant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent) Bharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vaxant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent)

For Appellant: Sh. Ajay Vohra, SrFor Respondent: Sh. NC Swain, CIT DR (OSD)
Section 201Section 254Section 40

201 of the Act, the assessing officer may be directed to allow the same in case appeal filed by the appellant against the said order is allowed by the Tribunal. xxii. For the aforesaid cumulative reasons, it is respectfully submitted that disallowance of Rs.866,59,50,444 made under section 40(a) of the Act is legally unsustainable and calls

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 1944/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2019AY 2012-13

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7637/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2019AY 2014-15

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 5026/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7112/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2019AY 2013-14

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 1308/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Nov 2019AY 2010-11

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 4913/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

transfer pricing adjustment made in the hands of the assesse. Ground of appeal Nos. 10 to 10.8 are thus allowed. 92. In the result, the appeal of the assessee is partly allowed. ITA No.7112/Del/2017 [Assessee’s appeal] Assessment Year: 2013-14 93. The assessee has raised following grounds of appeal relating to Assessment Year 2013-14:- 1. “That the assessing

BT E-SERV (INDIA) PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result, grounds Nos

ITA 6690/DEL/2016[2012-13]Status: DisposedITAT Delhi19 Jun 2018AY 2012-13

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Nageswar Rao, Adv., AdvFor Respondent: Shri Sanjay I. Prera, CIT DR
Section 10ASection 143(3)Section 144CSection 92CSection 92C(3)

section 271(1)(c) of the Act.” 3. The Ld. AR submitted that in the final set of comparables, the following 12 companies had been selected:- 1. Calibre Point Business Solutions Limited 2. e4e Healthcare Limited 3. Informed Technologies India Limited 4. Infosys BPO Limited 5. Jindal Intellicom Limited ITA 6690/Del/2016 Assessment year 2012-13 6. Microgenetics Systems Limited

MINDA FURUKAWA ELECTRIC PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

The appeals of the assessee stand partly allowed for statistical purposes

ITA 5444/DEL/2016[2009-10]Status: DisposedITAT Delhi27 Nov 2020AY 2009-10

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Surender Pal, CIT(DR)
Section 92C

section 271(l)(c) of the Act against the Appellant, which is bad in law. 3.0 With reference to assessee’s appeal for assessment year 2009-10, The Ld. AR submitted that this assessment year was the second year of incorporation of the company but only the first year of operations as the commercial production had started only in September

MINDA FURUKAWA ELECTRIC PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

The appeals of the assessee stand partly allowed for statistical purposes

ITA 5445/DEL/2016[2010-11]Status: DisposedITAT Delhi27 Nov 2020AY 2010-11

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Surender Pal, CIT(DR)
Section 92C

section 271(l)(c) of the Act against the Appellant, which is bad in law. 3.0 With reference to assessee’s appeal for assessment year 2009-10, The Ld. AR submitted that this assessment year was the second year of incorporation of the company but only the first year of operations as the commercial production had started only in September

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 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-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