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13 results for “section 68”+ Section 92Cclear

Sorted by relevance

Mumbai349Delhi338Bangalore178Ahmedabad74Kolkata63Pune49Hyderabad29Chennai25Jaipur18Indore13Surat7Dehradun6SC2Amritsar2Panaji2Karnataka2Raipur1

Key Topics

Section 143(3)11Transfer Pricing8Section 144C(13)6Addition to Income6Section 10A4Section 144C4TP Method4Section 144C(8)3Section 115J3Section 92C

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

section 92C(2), the assessee claimed that the mean PLI of 14.53% of external comparables yielded the acceptable lower range of 8.80% and higher rate of 20.25% of PLI. Therefore, the assessee claimed that its own PLI of 14.16% was within safe harbour range of mean PLI of comparables at Page 7 of 47 Computer Sciences Corporation India Private

3
Double Taxation/DTAA3
Section 282

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

ITA 602/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

68 in the immediately preceding assessment year. (xii) erred in deleting the addition of Rs. 94,11,950/- made on account of disallowance of interest made to certain parties who not existed in A.Y.2008-09 which has been rightly done by the AO to keep the issue alive. (xiii) erred in deleting the addition of Rs. 94,11,950/- made

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

ITA 601/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri O.P. Meena

68 in the immediately preceding assessment year. (xii) erred in deleting the addition of Rs. 94,11,950/- made on account of disallowance of interest made to certain parties who not existed in A.Y.2008-09 which has been rightly done by the AO to keep the issue alive. (xiii) erred in deleting the addition of Rs. 94,11,950/- made

THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

ITA 622/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

68 in the immediately preceding assessment year. (xii) erred in deleting the addition of Rs. 94,11,950/- made on account of disallowance of interest made to certain parties who not existed in A.Y.2008-09 which has been rightly done by the AO to keep the issue alive. (xiii) erred in deleting the addition of Rs. 94,11,950/- made

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

ITA 607/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri O.P. Meena

68 in the immediately preceding assessment year. (xii) erred in deleting the addition of Rs. 94,11,950/- made on account of disallowance of interest made to certain parties who not existed in A.Y.2008-09 which has been rightly done by the AO to keep the issue alive. (xiii) erred in deleting the addition of Rs. 94,11,950/- made

THE DCIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 265/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

92C (2), it was claimed that the transaction is within tolerance band of +/-5% Margin. 2.6.1. We find that there is no dispute between TPO and the assessee as regards the method, which is CPM and benchmarking based on internal comparable. The only dispute whether the assessee has justified for considering the aggregation of all the projects with

THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 349/IND/2016[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

92C (2), it was claimed that the transaction is within tolerance band of +/-5% Margin. 2.6.1. We find that there is no dispute between TPO and the assessee as regards the method, which is CPM and benchmarking based on internal comparable. The only dispute whether the assessee has justified for considering the aggregation of all the projects with

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 316/IND/2016[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

92C (2), it was claimed that the transaction is within tolerance band of +/-5% Margin. 2.6.1. We find that there is no dispute between TPO and the assessee as regards the method, which is CPM and benchmarking based on internal comparable. The only dispute whether the assessee has justified for considering the aggregation of all the projects with

M/S. ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS VA TECH HYDRO INDIA PRIVATE LIMITED),BHOPAL vs. THE DCIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 157/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

92C (2), it was claimed that the transaction is within tolerance band of +/-5% Margin. 2.6.1. We find that there is no dispute between TPO and the assessee as regards the method, which is CPM and benchmarking based on internal comparable. The only dispute whether the assessee has justified for considering the aggregation of all the projects with

THE ACIT, - 4(1), INDORE vs. M/S. YASH TECHNOLOGIES PVT. LTD., INDORE

In the result appeal of the revenue is dismissed

ITA 616/IND/2018[2014-15]Status: DisposedITAT Indore31 Oct 2019AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15 Pan : Aaacy1868M

Section 10ASection 115JSection 143(3)Section 28Section 40

68,143/- treating them to be the part of the expenditure of SEZ units. When the matter came up the Ld. CIT(A) deleted the impugned addition. 15. Now the revenue is in appeal before the Tribunal. 16. Ld. Departmental Representative vehemently argued supporting the orders of Ld. A.O. 17. Ld. Counsel for the assessee referred to the following written

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)

92C(2) of the Act. ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 Page 4 of 29 Corporate Tax related grounds 5. On the facts and in the circumstances of the case and in law, the ld AO/DRP has erred in disallowing an expense of Rs.6,07,00,658/- under Section

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)

92C(2) of the Act. ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 Page 4 of 29 Corporate Tax related grounds 5. On the facts and in the circumstances of the case and in law, the ld AO/DRP has erred in disallowing an expense of Rs.6,07,00,658/- under Section

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)

92C(2) of the Act. ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 Page 4 of 29 Corporate Tax related grounds 5. On the facts and in the circumstances of the case and in law, the ld AO/DRP has erred in disallowing an expense of Rs.6,07,00,658/- under Section