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.

19 results for “transfer pricing”+ Section 44Bclear

Sorted by relevance

Delhi19Mumbai13Dehradun6Chennai6Jodhpur1Lucknow1Chandigarh1Jaipur1Cuttack1

Key Topics

Section 143(3)29Section 153A28Addition to Income17Disallowance15Natural Justice15Section 26310Section 44B7Double Taxation/DTAA3Section 92Transfer Pricing

TATA NYK SHIPPING PTE. LTD. ,SINGAPORE vs. CIT INTERNATIONAL TAXATION-3, NEW DELHI

In the result, the appeal is allowed

ITA 1067/DEL/2022[2016-17]Status: DisposedITAT Delhi09 Mar 2023AY 2016-17

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2016-17 M/S. Tata Nyk Shipping Pte. Vs. Commissioner Of Income Tax, Ltd., International Taxation-3, 6, Shenton Way, #18-08B, New Delhi Oue Downtown 2, Singapore Pan :Aadct9945P (Appellant) (Respondent)

Section 142(1)Section 263Section 92C

Transfer Pricing Officer (TPO) to examine arm’s 3 AY: 2016-17 length nature of such transactions. After considering the order of the TPO passed under section 92CA(3) of the Act, the Assessing Officer ultimately completed the assessment vide order dated 14.06.2019 accepting the income declared by the assessee. The assessment order so passed was taken up for review

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

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

2
Permanent Establishment2
ITA 930/DEL/2020[2016-17]Status: DisposedITAT Delhi04 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

Section 115JSection 143(3)Section 250

44B or section 44BB or section 44BBA or section 44BBB and such income has been offered to tax at the rates specified in those sections. Explanation 5.—For the purposes of sub-section (2), the expression "securities" shall have the same meaning as assigned to it in clause (h) of section 2 of the Securities Contracts (Regulation

SHENHZHEN SDG INFORMATION CO. LTD.,DELHI vs. CIRCLE INT. TAXATION 3(1)(2), DELHI

Appeal is allowed

ITA 746/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Commissioner Of Income Tax, Shenhzhen Sdg Information Co. Ltd., International Taxation-3, C/O- Tass Advisors Llp, 62, New Delhi Lower Ground Floor, Pocket 2, Jasola, New Delhi Pan: Aavcs7426C (Appellant) (Respondent) Assessee By Sh. Divyanshu Agrawal, Adv. Sh. Anubhav Rastogi, Adv. Department By Sh. Vijay B Vasanta, Cit(Dr) Date Of Hearing 10.03.2025 Date Of Pronouncement 05.06.2025 Order

Section 263Section 44B

transfer pricing analysis. 8.6.2 Indian DTAAs follow relevant business activity approach to attribute profit to the PE. Under this approach, the arm's length profit would be what the independent party performing same of similar business activities under same or similar condition would earn. In a simpler term, it refers to the arm's length profit of the business activity

SIEM OFFSHORE CREWING AS,DEHRADUN vs. ACIT, INTL. TAXATION, DEHRADUN

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

ITA 4542/DEL/2013[2008-09]Status: DisposedITAT Delhi11 Mar 2016AY 2008-09

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastava

For Appellant: S/Shri Amit Arora, CA, Amit Bhalla, CA & Suraj Nangia, CAFor Respondent: Shri Anand Kumar Kadia, CIT DR
Section 234BSection 44BSection 9Section 9(1)(vii)

transfer pricing adjustment of Rs. 55,37,033/- deriving the margin (PLI) at 10.12% as per search of comparables made by him without considering the comparable margin submitted by the assessee. 3. On the facts and circumstances of the case, the Ld. CIT (A) has erred on the facts and law in treating the total gross receipts

ONGC AS REPRESENTATIVE ASSESSEE OF INTERNATIONAL HUMAN RESOURCES DEV.CORP.,,DEHRADUN vs. DEPUTY DIRECTOR OF INCOME-TAX, DEHRADUN

In the result, the appeal filed by the assessee is allowed

ITA 2486/DEL/2016[2010-11]Status: DisposedITAT Delhi22 Jan 2019AY 2010-11

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2010-11 Ongc As Representative Assessee Of Vs Deputy Director Of Income- International Human Resources Dev. Tax, International Taxation, Corporation, Circle-2, Aayakar Bhawan, Dgm-Head Corp. Tax, Ongc Ltd., 13A, Subhash Road, Room No.244, Old Secretariat Dehradun. Building, Tel Bhawan, Dehradun. Pan: Aaaco1598A

For Appellant: Shri Mohd. Farid, CAFor Respondent: Shri Amit Katoch, Sr. DR
Section 2Section 44BSection 9(1)(vi)

Section 9(1)(vi) of the Act. The relevant observation of the Assessing Officer reads as under:- “During the relevant previous year, payments were made by ONGC to International Human Resources Development Corporation, USA (hereinafter "non-resident’) under one tax protected contract dated 25.09.2009 for procurement to International Petroleum Industry Multimedia System (IPIMS) e-Leaming License and for development

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1342/DEL/2020[2014-15]Status: DisposedITAT Delhi09 May 2022AY 2014-15

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1343/DEL/2020[2015-16]Status: DisposedITAT Delhi09 May 2022AY 2015-16

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1344/DEL/2020[2016-17]Status: DisposedITAT Delhi09 May 2022AY 2016-17

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1197/DEL/2020[2011-12]Status: DisposedITAT Delhi09 May 2022AY 2011-12

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1198/DEL/2020[2012-13]Status: DisposedITAT Delhi09 May 2022AY 2012-13

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1201/DEL/2020[2015-16]Status: DisposedITAT Delhi09 May 2022AY 2015-16

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1339/DEL/2020[2011-12]Status: DisposedITAT Delhi09 May 2022AY 2011-12

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1340/DEL/2020[2012-13]Status: DisposedITAT Delhi09 May 2022AY 2012-13

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1199/DEL/2020[2013-14]Status: DisposedITAT Delhi09 May 2022AY 2013-14

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1202/DEL/2020[2016-17]Status: DisposedITAT Delhi09 May 2022AY 2016-17

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1338/DEL/2020[2010-11]Status: DisposedITAT Delhi09 May 2022AY 2010-11

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1200/DEL/2020[2014-15]Status: DisposedITAT Delhi09 May 2022AY 2014-15

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1196/DEL/2020[2010-11]Status: DisposedITAT Delhi09 May 2022AY 2010-11

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1341/DEL/2020[2013-14]Status: DisposedITAT Delhi09 May 2022AY 2013-14

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing