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91 results for “disallowance”+ TP Methodclear

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Key Topics

Section 143(3)105Transfer Pricing58Section 92C50Comparables/TP48Addition to Income44Deduction29Section 10A26Section 14825Disallowance24

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144Section 80Section 801BSection 80J

method of benchmarking the market value, i.e., the price at which the third party sells the goods to the non-eligible units of the assessee company, had been upheld by the Hon'ble Apex Court in the case of Jindal Steel Power Ltd (supra), and by the ITAT, 35 ITA TP 466/Hyd/2022 and 1301/Hyd/2024 Dodla Dairy Limited. Chennai

ZUARI CEMENT LIMITED,KADAPA vs. DCIT, CIRCLE -1, KURNOOL

Showing 1–20 of 91 · Page 1 of 5

TP Method21
Section 54B20
Section 144C(5)17

In the result, both the appeals preferred by the assessee are treated as allowed for statistical purposes

ITA 132/HYD/2022[2017-18]Status: DisposedITAT Hyderabad15 Feb 2023AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Zuari Cement 249/Hyd/2021 2016-17 Dcit, Limited, Circle-1, Yerraguntla, Kurnool Kadapa District 132/Hyd/2022 2017-18 [Pan: Aaacz1270E]

For Appellant: Shri Deepak Chopra &For Respondent: Shri Jeevan Lal Lavidiya, CIT-DR
Section 143(3)

disallowances made by the TPO out of various payments made to AE. Each ground has sub grounds which are more or less in the form of submissions. 11. Ld.AR submitted that TPO erred in rejecting the transfer pricing documentation as well as TNMM as most appropriate Page 10 of 17 ITA-TP Nos. 249/Hyd/2021 & 132/Hyd/2022 method

ZUARI CEMENT LIMITED ,KADAPA vs. DEPUTY COMMISSIONER OF INCOME TAX ,CIRCLE-1, KURNOOL

In the result, both the appeals preferred by the assessee are treated as allowed for statistical purposes

ITA 249/HYD/2021[2016-17]Status: DisposedITAT Hyderabad15 Feb 2023AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Zuari Cement 249/Hyd/2021 2016-17 Dcit, Limited, Circle-1, Yerraguntla, Kurnool Kadapa District 132/Hyd/2022 2017-18 [Pan: Aaacz1270E]

For Appellant: Shri Deepak Chopra &For Respondent: Shri Jeevan Lal Lavidiya, CIT-DR
Section 143(3)

disallowances made by the TPO out of various payments made to AE. Each ground has sub grounds which are more or less in the form of submissions. 11. Ld.AR submitted that TPO erred in rejecting the transfer pricing documentation as well as TNMM as most appropriate Page 10 of 17 ITA-TP Nos. 249/Hyd/2021 & 132/Hyd/2022 method

ADP PRIVATE LIMITED,HYDERABAD, TELANGANA vs. DCIT., CIRCLE 1(1), HYDERABAD, TELANGANA

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 332/HYD/2025[2021-22]Status: DisposedITAT Hyderabad10 Dec 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 195(2)Section 40

method with OP/OC as the PLI. After considering the TP documentation and submissions, the TPO made an adjustment of Rs. 13,87,33,384/- in respect of interest on delayed receivables from AE by applying the SBI short-term 11 ADP Private Limited deposit rate and allowing a credit period of 60 days, vide order dated 30.01.2024 passed under Section

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

ITA 254/HYD/2017[2012-13]Status: DisposedITAT Hyderabad27 Jun 2022AY 2012-13

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

For Appellant: Shri Deepak Chopra and Shri Nitin Narang, AdvocatesFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 143(3)

TP analysis is restored to the file of AO for fresh consideration. The grounds raised are accordingly allowed for statistical purposes.” 5. The Revenue vehemently contended that the learned lower authorities have rightly adopted a direct method i.e., CUP which carries precedence over all other indirect methods; including TNMM, as per Serdia Pharmaceutical India Pvt. Ltd Vs. ACIT

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

ITA 182/HYD/2018[2013-14]Status: DisposedITAT Hyderabad27 Jun 2022AY 2013-14

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

For Appellant: Shri Deepak Chopra and Shri Nitin Narang, AdvocatesFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 143(3)

TP analysis is restored to the file of AO for fresh consideration. The grounds raised are accordingly allowed for statistical purposes.” 5. The Revenue vehemently contended that the learned lower authorities have rightly adopted a direct method i.e., CUP which carries precedence over all other indirect methods; including TNMM, as per Serdia Pharmaceutical India Pvt. Ltd Vs. ACIT

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

ITA 66/HYD/2019[2014-15]Status: DisposedITAT Hyderabad27 Jun 2022AY 2014-15

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

For Appellant: Shri Deepak Chopra and Shri Nitin Narang, AdvocatesFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 143(3)

TP analysis is restored to the file of AO for fresh consideration. The grounds raised are accordingly allowed for statistical purposes.” 5. The Revenue vehemently contended that the learned lower authorities have rightly adopted a direct method i.e., CUP which carries precedence over all other indirect methods; including TNMM, as per Serdia Pharmaceutical India Pvt. Ltd Vs. ACIT

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

ITA 616/HYD/2016[2011-12]Status: DisposedITAT Hyderabad27 Jun 2022AY 2011-12

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

For Appellant: Shri Deepak Chopra and Shri Nitin Narang, AdvocatesFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 143(3)

TP analysis is restored to the file of AO for fresh consideration. The grounds raised are accordingly allowed for statistical purposes.” 5. The Revenue vehemently contended that the learned lower authorities have rightly adopted a direct method i.e., CUP which carries precedence over all other indirect methods; including TNMM, as per Serdia Pharmaceutical India Pvt. Ltd Vs. ACIT

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

ITA 2169/HYD/2018[2012-13]Status: DisposedITAT Hyderabad27 Jun 2022AY 2012-13

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

For Appellant: Shri Deepak Chopra and Shri Nitin Narang, AdvocatesFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 143(3)

TP analysis is restored to the file of AO for fresh consideration. The grounds raised are accordingly allowed for statistical purposes.” 5. The Revenue vehemently contended that the learned lower authorities have rightly adopted a direct method i.e., CUP which carries precedence over all other indirect methods; including TNMM, as per Serdia Pharmaceutical India Pvt. Ltd Vs. ACIT

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 104/HYD/2022[2017-18]Status: DisposedITAT Hyderabad23 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Vartik Choksi, ARFor Respondent: Ms. K. Haritha, CIT-DR
Section 143(3)Section 80ISection 92CSection 92E

TP) 104/Hyd/2022 Sanghi Industries Limited deduction U/s. 80IA in return of income, and no addition whatsoever was warranted to the total income. 3. That in the facts and circumstances of the case, the Ld. AO is not justified in making addition of downward adjustment of Rs. 154,38,00,527/- to the final assessable income instead of re-computing

ACIT., CIRCLE-5(1), HYDERABAD vs. MYLAN LABORATORIES LIMITED, HYDERABAD

In the result. appeal of the Assessee is partly allowed for statistical purposes and appeal of Revenue is partly allowed for statistical purposes

ITA 708/HYD/2022[2016-17]Status: DisposedITAT Hyderabad06 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: [Through Hybrid Hearing]For Respondent: MS. M. Narmada, CIT-DR
Section 115JSection 92C

disallowance u/se.14A of the Act. 8. Aggrieved by the order of the learned CIT(A), the appellant company and the Revenue are now in appeal before the Tribunal. 9. The first issue that came-up for consideration from grounds of appeal of the appellant company is, TP adjustment in respect of sale of API segment and Project Development Segment

ADAMA INDIA PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(3), HYDERABAD

In the result, appeal of the assessee is partly allowed

ITA 2314/HYD/2018[2014-15]Status: DisposedITAT Hyderabad03 Jul 2019AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15 Adama India Pvt. Ltd., Vs. Income-Tax Officer, Hyderabad. Ward – 1(3), Hyderabad. Pan – Aabcm 09294F (Appellant) (Respondent) Assessee By : Shri Raghunathan S. Revenue By : Shri Y.V.S.T. Sai Date Of Hearing : 09-04-2019 Date Of Pronouncement : 03-07-2019 O R D E R

For Appellant: Shri Raghunathan SFor Respondent: Shri Y.V.S.T. Sai
Section 115JSection 143(2)Section 143(3)Section 92CSection 92C(1)

TP study. You cannot adopt a method which is not embedded in the study. It is difficult to prove the services in terms of numbers but it can be seen only in ease of doing business in India and satisfaction of the farmers who are availing the services. Without the integrated services, the assessee would not have achieved the results

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

ITA 2186/HYD/2017[2013-14]Status: DisposedITAT Hyderabad27 Apr 2018AY 2013-14

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Deepak P. Ripote
Section 132Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 92B

TP study conducted by assessee: The assessee has carried out the economic analysis and has summarized it as under: Nature of Amount (Rs.) MAM PLI Margin of Margin of international assessee compalrable transaction Investment 12,68,25,000/- - - - - in subsidiary Corporate 13,58,87,500/- - - - - Guarantee M/s BS Ltd., Hyd. 2.4 Analysis of the Transaction: As per the audited statement

INVESCO(INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -2 (1), HYDERABAD

In the result, appeal of the Assessee is partly allowed for statistical purposes

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

disallowance u/sec.14A read with Rule 8D of I.T. Rules, 1962. 4. The appellant-company filed it’s objections against the Draft Assessment Order passed by the 10 ITA.No.111/Hyd./2022 Assessing Officer before the DRP-1, Bengaluru and challenged the various additions made by the Assessing Officer including TP adjustment as suggested by the TPO. The DRP vide

NETCRACKER TECHNOLOGY SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 730/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Dec 2025

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C(3)

method with profit level indicator of OP/OC of 17.45%. Further, the assessee has selected 14 comparables of similar nature with an OP/OC of 17.57% and claimed that, its transactions with AE are at arm's length price. The TPO, after considering relevant TP study document submitted by the assessee and also taking note of various facts, has made TP adjustment

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Appeal is allowed in above terms

ITA 181/HYD/2018[2009-10]Status: DisposedITAT Hyderabad24 Sept 2021AY 2009-10

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2009-10

For Appellant: Sri Deepak Chopra - ARFor Respondent: Smt. Anjala Sahu - DR
Section 143(3)

TP study conducted by the taxpayer. He also held that aggregation of transactions were not allowed and relied on the decisions of the co- ordinate bench in the case of Star India P. Ltd., Vs. ACIT [2008-TIOL-426- ITAT-MUM] and also UCB India Pvt. Ltd., [317 ITR 292 (AT) (Mum)], to come 6 to a conclusion that

GSS INFOTECH LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

ITA 2255/HYD/2017[2013-14]Status: DisposedITAT Hyderabad23 Jan 2020AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Smt. Y.V.S.T. Sai
Section 143(3)Section 92C

TP documentation by the TPO. The assessee did not seriously contest this ground and, therefore, the same is not adjudicated. 12. Ground No. 4 is against the rejection of CUP method as the most appropriate method and also rejecting the internal TNMM method adopted by the assessee. Sub-grounds of 30 I.T.A. No. 2255/Hyd/17 and others M/s GSS Infotech

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

ITA 2367/HYD/2018[2014-15]Status: DisposedITAT Hyderabad23 Jan 2020AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Smt. Y.V.S.T. Sai
Section 143(3)Section 92C

TP documentation by the TPO. The assessee did not seriously contest this ground and, therefore, the same is not adjudicated. 12. Ground No. 4 is against the rejection of CUP method as the most appropriate method and also rejecting the internal TNMM method adopted by the assessee. Sub-grounds of 30 I.T.A. No. 2255/Hyd/17 and others M/s GSS Infotech

AUROBINDO PHARMA LIMITED,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

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

ITA 172/HYD/2023[2019-20]Status: DisposedITAT Hyderabad19 Feb 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.172/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2019-20) Aurobindo Pharma Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aabca7366H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.G. Reddy, Advocate राज" व "ारा/Revenue By:: Smt. M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/01/2025 घोषणा की तारीख/Pronouncement: 19/02/2025 आदेश/Order

For Appellant: Shri B.G. Reddy, AdvocateFor Respondent: : Smt. M Narmada, CIT(DR)
Section 10ASection 143(3)Section 35Section 92C

disallowance pertaining to additional depreciation amounting to Rs. 27,19,777/- Page 3 of 18 ITA No 172 of 2023 Aurobindo Pharma Ltd despite directions by the Honourable DRP in this regard allowing the same as eligible expenditure. General 1. Any other ground that may be urged at the time of hearing with the previous approval

CAMBRIDGE TECHNOLOGY ENTERPRISES LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), HYDERABAD

In the result assessee’s appeal stand partly allowed

ITA 208/HYD/2018[2013-14]Status: DisposedITAT Hyderabad19 Nov 2019AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Appellant: Sh. P. Murali Mohana Rao, A.RFor Respondent: Sh. YVST Sai, CIT, D.R
Section 115JSection 143(1)Section 143(3)Section 92C

method. 2.1. Erred in not following the procedure laid down under the provisions of section 92C of the Act relating to the 'Computation of arms length price' for analyzing the said transaction. 2.2. DRP Erred in enhancing the ALP adjustment to Rs.4,61,30,226/- from Rs.3,24,48,315/- without issuing any show cause notice to the assessee