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6 results for “transfer pricing”+ TP Methodclear

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Key Topics

Section 92B21Section 26310Section 143(3)7Section 92C7Transfer Pricing5Section 80I4Addition to Income4Section 40A2Section 115J

GREENPLY INDUSTRIES LIMITED,TINSUKIA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA

In the result, the appeal of the assessee for A

ITA 232/GTY/2019[2014-15]Status: DisposedITAT Guwahati21 Jun 2022AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

transfer pricing adjustment was deleted by the ld. CIT(Appeals) by observing as follows:- “6.3. I have carefully considered the matter. It is seen that the TPO had agreed with TNMM method adopted by assessee. The only reason given by the TPO for making TP

ACIT, CIRCLE - TINSUKIA , TINSUKIA vs. M/S. GREENPLY INDUSTRIES LTD., TINSUKIA

In the result, the appeal of the assessee for A

2
Section 143(2)2
Exemption2
Deduction2
ITA 359/GTY/2019[2014-15]Status: Disposed
ITAT Guwahati
21 Jun 2022
AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

transfer pricing adjustment was deleted by the ld. CIT(Appeals) by observing as follows:- “6.3. I have carefully considered the matter. It is seen that the TPO had agreed with TNMM method adopted by assessee. The only reason given by the TPO for making TP

ASSAM BIO ETHANOL PRIVATE LIMITED,GUWAHATI vs. ITO W-1(1), GUWAHATI, GUWAHATI

Appeal is partly allowed

ITA 288/GTY/2024[2021-22]Status: DisposedITAT Guwahati16 Oct 2025AY 2021-22

Bench: The Drp Was That The

Section 143(3)Section 144Section 144C(3)

transfer pricing report, which had taken into consideration all possible and permissible methods of computing Arm’s Length Price (ALP) and had, with good reasons, rejected all of them and adopted “other method” as prescribed under Rule 10AB. The Ld. AR pointed out on page 133 of the paper book that the “other method” was adopted after a detailed analysis

M/S. BHARTIA-SMSIL(JV),GUWAHATI vs. INCOME TAX OFFICER, WARD-3(1), GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 117/GTY/2019[2014-15]Status: DisposedITAT Guwahati17 Jun 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.117/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Sanjay Modi, FCAFor Respondent: Shri M.K. Dal, Addl. CIT, Sr. Dr
Section 143(3)Section 263Section 3Section 92BSection 92C

Transfer Pricing Officer(TPO) under section 92CA related party transactions amounting to Rs.51,08,99,031/- which is falling within the meaning of'specified domestic transactions' under section 92BA(i) of the Income Tax Act, 1961 to arrive at the Arm's Length Price (ALP) u/s 92C of the Act as required in terms of CBDT InstructionNo. 3/2016 dated

SHIVANI ISPAT AND ROLLING MILL (P) LTD.,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 227/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.227/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shivani Ispatand Rolling Mill Vs. Acit, Circle-Shillong (P) Ltd. 13Th Mile, Tamulkuchi, Byrnihat, G.S. Road, Ri-Bhoi, Meghalaya "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aafcs 3465 B (Appellant) .. (Respondent) Appellant By :Shri J.P. Gupta, Fca Respondent By :Shri T. Hunar, Jcit, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 15/06/2020 घोषणाक"तार"ख/Date Of Pronouncement : 31/07/2020 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15, Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeal)- Shillong, In Appeal No. Cit(A)/Shg/10083/2018-19 Dated 17.04.2019, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) / 92C(4) / 263 Of The Income Tax Act, 1961 (In Short The ‘Act’) Dated 30/11/2018. 2.When This Appeal Was Called Out For Hearing, The Ld. Counsel For The Assessee Invited Our Attention To The Order Dated 10.06.2020, Passed By The Tribunal In The Case Of M/S Raipur Steel Casting India (P) Ltd. & Srinath Ji Furnishing Pvt. Ltd. In I.T.A. No. 895& 1035/Kol/2019, For Assessment Year 2014-15.Wherein Thetribunal Held That Effect Of Omission Of Clause (I) Of Section 92Ba W.E.F 01.04.2017 Had The Effect Of It Being Omitted From Its Inception Hence, Reference

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

method used to determine the arm`s length price for specified domestic transactions, positions taken with regard to certain transactions not covered as specified domestic transactions etc. This has considerable increased the compliance burden of the taxpayers. In order to reduce the compliance burden of the taxpayers, it was proposed by the Finance Act 2017 to provide that expenditure

SHREE SAI SMELTERS (I) LIMITED,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 228/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.228/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shree Shai Smelters (I) Ltd. Vs. Acit, Circle-Shillong

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

method used to determine the arm`s length price for specified domestic transactions, positions taken with regard to certain transactions not covered as specified domestic transactions etc. This has considerable increased the compliance burden of the taxpayers. In order to reduce the compliance burden of the taxpayers, it was proposed by the Finance Act 2017 to provide that expenditure