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8 results for “transfer pricing”+ Section 920clear

Sorted by relevance

Mumbai135Delhi53Bangalore25Ahmedabad20Jaipur15Chennai11Hyderabad8Kolkata6Pune5Indore5Lucknow4Visakhapatnam2Cochin2Rajkot2Cuttack2Varanasi1

Key Topics

Section 80G22Section 569Section 14A7Addition to Income7Section 143(3)6Transfer Pricing5Section 56(2)(viia)4Section 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
Disallowance4
Section 143(2)3
Comparables/TP3

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

Transfer Pricing adjustment of INR 2,70,56,964/-. This adjustment was made by the Assessing Officer (AO) pursuant to directions from the Dispute Resolution Panel (DRP). The dispute revolves around the determination of the Arm's Length Price (ALP) for international transactions related to IT services provided by the assessee to its associated enterprises (AEs). The assessee's primary

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\nfor statistical purposes

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

920/-. In view of the\ninternational transactions involved during the year under\nconsideration, for determination of Arm's Length Price (\"ALP\"), the\ncase of the assessee was referred to Learned Transfer Pricing Officer\n(“Ld. TPO\"). The Ld. TPO vide his order dated 31.10.2018\nsuggested upward adjustment of Rs.18,87,93,975/- on account of\nSDS.\nSubsequently

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

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

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

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