BharatTax.net
SearchITATHigh CourtsSupreme CourtAI 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.

10 results for “transfer pricing”+ Section 44Cclear

Sorted by relevance

Mumbai42Delhi10Ahmedabad3Kolkata2

Key Topics

Section 14716Section 1488Double Taxation/DTAA7Disallowance5Section 143(2)4Section 44C4Section 139(1)4Section 133A4Section 1314Section 374Permanent Establishment4Business Income4

AVL TECHNICAL CENTRE PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-3(2), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 7705/DEL/2019[2008-09]Status: DisposedITAT Delhi11 Dec 2025AY 2008-09

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhriasstt. Year: 2008-09 Avl Technical Private Limited, Vs Dcit Csc, C-9, Vasant Kunj, Central Circle-3(2) New Delhi-70 New Delhi (Appellant) (Respondent) Pan No. Aadca1470C

For Appellant: Shri Vishal Kalra, Adv. &For Respondent: Shri S.K. Jhadav, CIT( DR)
Section 133(6)Section 143(3)Section 144CSection 14ASection 254Section 92C

transfer pricing study.” 3. Brief facts of the case are that the assessee filed return for A.Y. 2008-09 on 25.09.2008, declaring a loss of Rs. 3,46,86,270/- . The case was taken up for scrutiny and a reference was made to the TPO as per provisions of section 92CA

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),GURGAON vs. ITO,WARD-14(3), NEW DELHI

In the result, the appeal filed by the assessee being ITA

ITA 2061/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

transfer pricing and corporate tax matters to the Ld. TPO and Ld. AO for consideration and thereafter passing a speaking order, which is in gross violation of section I 44C

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),HARYANA vs. ITO,WARD 14 (3) , NEW DELHI

In the result, the appeal filed by the assessee being ITA

ITA 2060/DEL/2022[2017-18]Status: DisposedITAT Delhi21 Mar 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

transfer pricing and corporate tax matters to the Ld. TPO and Ld. AO for consideration and thereafter passing a speaking order, which is in gross violation of section I 44C

BOMBARDIER TRANSPORTATION GMBH,NEW DELHI vs. DCIT, CIRCLE- 1(1)(2), INTL. TAXATION, NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 5638/DEL/2018[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Anmol Anand, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT DR

Pricing Officer in his order dated 25.11.2014 passed u/s 92CA(3) of the Act has drawn no adverse inference in respect of the international transaction undertaken by the assessee during the year. The assessee company entered into a contract dated 19th July 2007 with DMRC transfer of technology in respect of passenger rolling stock ('Contract RS2'). During

M/S. BOMBARDIER TRANSPORTATION GMBH SCHONEBERGERUFER 1,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 872/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Anmol Anand, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT DR

Pricing Officer in his order dated 25.11.2014 passed u/s 92CA(3) of the Act has drawn no adverse inference in respect of the international transaction undertaken by the assessee during the year. The assessee company entered into a contract dated 19th July 2007 with DMRC transfer of technology in respect of passenger rolling stock ('Contract RS2'). During

DIRECTOR OF INCOME TAX

ITA/504/2007HC Delhi23 Dec 2011

44C @ 5% = 1,78,93,130/- Taxable Income = 33,99,69,471/- Tax @ 55% = 18,69,83,209/- ……………. I Total consideration for software – US $ 1,10,72,708/- Converted into INR @ 36.15 – 40,02,78,394/- Tax @ 30% = Rs/12.00.83.513/- …………… II Total tax = (I) + (II) = 30,70,66,727/- Assessed. Issue necessary forms. Charge interest Penalty proceedings

SPRINGER VERLAG GMBH vs. DDIT, CIRCLE-2(2),,

ITA 644/DEL/2005[2000-2001]Status: DisposedITAT Delhi04 Jan 2024AY 2000-2001

Bench: G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Sanjeev Chaudhary, ARFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 131Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 44C

44C of the Act. 4. As far as the first issue of validity of reopening of assessment under section 147 of the Act is concerned, briefly, the facts are, the assessee is a non-resident corporate entity incorporated in Germany and a tax resident of Germany. As stated, the assessee is a pioneer in publishing scientific, technical, medical books

SPRINGER VERLAG GMBH vs. DDIT, CIRCLE-2(2),,

ITA 643/DEL/2005[1999-2000]Status: DisposedITAT Delhi04 Jan 2024AY 1999-2000

Bench: G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Sanjeev Chaudhary, ARFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 131Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 44C

44C of the Act. 4. As far as the first issue of validity of reopening of assessment under section 147 of the Act is concerned, briefly, the facts are, the assessee is a non-resident corporate entity incorporated in Germany and a tax resident of Germany. As stated, the assessee is a pioneer in publishing scientific, technical, medical books

SPRNGER VERLAG GMBH vs. DDIT, CIRCLE-2(2),,

ITA 645/DEL/2005[2001-2002]Status: DisposedITAT Delhi04 Jan 2024AY 2001-2002

Bench: G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Sanjeev Chaudhary, ARFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 131Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 44C

44C of the Act. 4. As far as the first issue of validity of reopening of assessment under section 147 of the Act is concerned, briefly, the facts are, the assessee is a non-resident corporate entity incorporated in Germany and a tax resident of Germany. As stated, the assessee is a pioneer in publishing scientific, technical, medical books

SPRINGER VERLAG GMBH,NEW DELHI vs. DDIT, NEW DELHI

ITA 3660/DEL/2009[2002-03]Status: DisposedITAT Delhi04 Jan 2024AY 2002-03

Bench: G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Sanjeev Chaudhary, ARFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 131Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 44C

44C of the Act. 4. As far as the first issue of validity of reopening of assessment under section 147 of the Act is concerned, briefly, the facts are, the assessee is a non-resident corporate entity incorporated in Germany and a tax resident of Germany. As stated, the assessee is a pioneer in publishing scientific, technical, medical books