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142 results for “disallowance”+ Transfer Pricingclear

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Key Topics

Section 271D182Section 143(3)115Section 269S78Section 8074Section 26356Section 12A54Section 10(38)53Addition to Income47Section 80I41Exemption

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

transfer-pricing at Rs. 37,69,02,830/- as per TPO’s order (ii) re-working of exemption u/s 10A/10B, (iii) capitalization of civil & tiling work in leasehold premise, (iv) depreciation on software, and (v) disallowance

Showing 1–20 of 142 · Page 1 of 8

...
33
Disallowance31
Deduction27

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 227/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

price, contract specifications, brokerage charges, etc., along with ledger accounts of the brokers and all the transactions were effected through normal banking channels. CO Nos.2 to 4/Ind/2022 6.1 From the assessment order, we also note that the AO has also not controverted the fact that the assessee had traded on NMCE through registered brokers as their client and their trading

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 226/IND/2021[2012-2013]Status: DisposedITAT Indore30 Jan 2023AY 2012-2013

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

price, contract specifications, brokerage charges, etc., along with ledger accounts of the brokers and all the transactions were effected through normal banking channels. CO Nos.2 to 4/Ind/2022 6.1 From the assessment order, we also note that the AO has also not controverted the fact that the assessee had traded on NMCE through registered brokers as their client and their trading

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 235/IND/2021[2011-12]Status: DisposedITAT Indore30 Jan 2023AY 2011-12

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

price, contract specifications, brokerage charges, etc., along with ledger accounts of the brokers and all the transactions were effected through normal banking channels. CO Nos.2 to 4/Ind/2022 6.1 From the assessment order, we also note that the AO has also not controverted the fact that the assessee had traded on NMCE through registered brokers as their client and their trading

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

price, contact specification and brokerage charges etc. with ledger accounts of the brokers and all the transactions were undertaken through banking channels by paying brokerage to the respective brokers. We also note a very important fact that the respective exchange has also confirmed the transaction carried by the appellate and there is no allegation by the AO to the fact

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

price, contact specification and brokerage charges etc. with ledger accounts of the brokers and all the transactions were undertaken through banking channels by paying brokerage to the respective brokers. We also note a very important fact that the respective exchange has also confirmed the transaction carried by the appellate and there is no allegation by the AO to the fact

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

ITA 982/IND/2019[2015-16]Status: DisposedITAT Indore30 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

Section 143(3)Section 144CSection 144C(5)

price determined by the Assessee. 7. Inappropriate disallowance of claim of INR 72,992/- under section 10AA Page 4 of 22 Cummins Technologies India P. ltd. Page 5 of 22 7.1 On the facts and in circumstances of the case and in law, the learned AO pursuant to the directions of Hon'ble DRP, has erred in disallowance of claim

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 179/IND/2016[2011-12]Status: DisposedITAT Indore10 Apr 2023AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6) of the Act. 4.7 Considering companies as comparable to the appellant despite such companies failing test of comparability or failure of TPO’s own filer

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 319/IND/2018[2013-14]Status: DisposedITAT Indore10 Apr 2023AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6) of the Act. 4.7 Considering companies as comparable to the appellant despite such companies failing test of comparability or failure of TPO’s own filer

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 292/IND/2017[2012-13]Status: DisposedITAT Indore10 Apr 2023AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6) of the Act. 4.7 Considering companies as comparable to the appellant despite such companies failing test of comparability or failure of TPO’s own filer

ACIT-2(1), UJJAIN, UJJAIN vs. M/S RUCHI J OIL PVT. LTD,, MUMBAI

In the result, Revenue’s appeal ITANo

ITA 82/IND/2020[2014-15]Status: HeardITAT Indore17 Jan 2022AY 2014-15

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year: 2014-15

Section 271ASection 40A(2)(b)Section 91D(1)Section 92BSection 92D(1)

Pricing Officer (TPO) and stated that the TPO has considered purchase of undertaking by way of slump sale from Ruchi Soya Industries Ltd. as a Specified Domestic Transaction. ii) Thereafter, in para 5.5.2 of the order the AO stated “Therefore, the order of Ld. TPO u/s 92CA as regards valuation of the above transaction and the categorization of the same

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 139/IND/2024[2018-19]Status: DisposedITAT Indore01 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL, MADHYA PRADESH vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 113/IND/2024[2014-15]Status: DisposedITAT Indore01 Jan 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

ITA 143/IND/2024[2018-19]Status: DisposedITAT Indore01 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 137/IND/2024[2015-16]Status: DisposedITAT Indore01 Jan 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

ITA 142/IND/2024[2016-17]Status: DisposedITAT Indore01 Jan 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

INDORE DEVELOPMENT AUTHORITY,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

ITA 141/IND/2024[2015-16]Status: DisposedITAT Indore01 Jan 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT ( EXEMPTION CIRCLE) , BHOPAL

Appeals are allowed and revenue’s appeals

ITA 144/IND/2024[2021-22]Status: DisposedITAT Indore01 Jan 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

DEPUTY COMMISSIONER OF INCOME TAX, EXEMPTION, BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE, INDORE

Appeals are allowed and revenue’s appeals

ITA 136/IND/2024[2021-22]Status: DisposedITAT Indore01 Jan 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 138/IND/2024[2016-17]Status: DisposedITAT Indore01 Jan 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

Transfer Expenses”. It is this expenditure which the AO has disallowed. The main reasoning which the AO has assigned for disallowance is when the assessee is no longer owner of schemes, why the expenditure would be incurred by assessee? The Ld. AR for assessee has drawn our attention to the charts giving complete details of the schemes and expenses incurred