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9 results for “transfer pricing”+ Section 920clear

Sorted by relevance

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Key Topics

Section 80G22Section 569Section 143(3)7Section 14A7Addition to Income7Transfer Pricing6Section 92C5Section 80I4Section 135

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

transfer of any goods or services of the eligible business carried out by the assessee to any other business carried out by it. Similarly, section 80IA(10) reads as under : Where it appears to the Assessing Officer that, owing to the close connection between the assessee carrying on the eligible business to which this section applies and any other person

4
Section 56(2)(viia)4
Comparables/TP4
Disallowance4

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

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

ITA 1187/HYD/2018[2014-15]Status: DisposedITAT Hyderabad28 Apr 2023AY 2014-15

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

For Appellant: Shri Sriram Seshadri, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 14A(3)Section 47Section 56Section 56(2)(viia)Section 56(2)(viiia)

section 147 / 148 of the Act, the coordinate Bench had held as under : “22. Coming back to our point we have to examine whether protective assessment/addition is possible under section 147 in respect of the same person and for the same period. When a regular assessment is made and later on it comes to the notice of the Assessing Officer

SSNC FINTECH SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 8(1), HYDERABAD

ITA 916/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Jul 2025

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Ketan K. VedFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 920

transfer pricing (TP) study report maintained as per section 920 of the Income Tax Act, 1961 ('the Act') read with

XILINX INDIA TECHNOLOGY SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

ITA 1761/HYD/2019[2015-16]Status: DisposedITAT Hyderabad08 Aug 2025AY 2015-16
For Appellant: Shri SP Chidambaram, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

transfer pricing documentation maintained by the Appellant in accordance with the provisions of the Act read with the Income-tax Rules, 1962 ('Rules') and undertaking a fresh economic analysis during the course of assessment proceedings and thereby making an adjustment of Rs. 11,85,12,793 to the international transactions relating to provision of software development services. That

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED., HYD,HYDERABAD vs. DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD

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

ITA 87/HYD/2017[2012-13]Status: DisposedITAT Hyderabad08 Jun 2018AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2012-13 Hyundai Motor India Engg. Pvt. Vs. Dy. Commissioner Of Income- Ltd., Hyderabad Tax, Circle – 2(2), Hyderabad.

For Appellant: Shri K.R. VasudevanFor Respondent: Shri K. Srinivasa Reddy
Section 139(1)Section 143(3)Section 92C

920/-, and hence, reference was made to the Transfer Pricing Officer (TPO) with prior approval of Pr. CIT – 2, Hyderabad for determining Arm’s Length Price u/s 92CA of the IT Act. 2.2 Assessee’s Profile: The assessee company is engaged in providing/rendering R&D support services in respect of CAD and CAE tools in designing the automobile parts

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD vs. ALPHA VILLAS PRIVATE LIMITED, HYDERABAD

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

ITA 1106/HYD/2017[2011-12]Status: DisposedITAT Hyderabad12 Jun 2023AY 2011-12

Bench: Shri R.K. Panda & Shri K. Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Shri Jeevan Lal Lavidiya, CIT(DR)
Section 143(2)Section 56

920 72,99,24,480 73,49,93,400 from Bharathi Cements (Rs.6,600 treated as misc. charges) Total 6,89,649 68,96,490 99,30,94,560 99,99,91,050 The appellant further submitted as follows : Page 4 of 22 ITA Nos 1106 and 1107 of 2017 Alpha Villas Pvt Ltd A. In the assessment order

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD vs. ALPHA AVENUES PRIVATE LIMITED, HYDERABAD

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

ITA 1107/HYD/2017[2011-12]Status: DisposedITAT Hyderabad12 Jun 2023AY 2011-12

Bench: Shri R.K. Panda & Shri K. Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Shri Jeevan Lal Lavidiya, CIT(DR)
Section 143(2)Section 56

920 72,99,24,480 73,49,93,400 from Bharathi Cements (Rs.6,600 treated as misc. charges) Total 6,89,649 68,96,490 99,30,94,560 99,99,91,050 The appellant further submitted as follows : Page 4 of 22 ITA Nos 1106 and 1107 of 2017 Alpha Villas Pvt Ltd A. In the assessment order

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

ITA 482/HYD/2022[2018-19]Status: DisposedITAT Hyderabad16 Aug 2023AY 2018-19

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Nageswar Rao, AR
Section 135Section 143(3)Section 234BSection 37Section 80GSection 80G(2)

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

ITA 145/HYD/2022[2017-18]Status: DisposedITAT Hyderabad16 Aug 2023AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Nageswar Rao, AR
Section 135Section 143(3)Section 234BSection 37Section 80GSection 80G(2)

transfer pricing adjustment qua the provision of IT services. 3. When the assessee filed objections before the learned DRP, learned DRP, while confirming the disallowance of deduction under section 80G of the Act, issued certain directions. Though the assessee filed this appeal on several grounds, many grounds were withdrawn, stating the assessee had relief in respect of some issues