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79 results for “transfer pricing”+ Carry Forward of Lossesclear

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Key Topics

Section 143(3)129Section 8087Section 14774Section 80I57Addition to Income54Disallowance47Section 153A41Section 6840Section 12A36

ANDRITZ HYDRO P LTD,BHOPAL vs. PR CIT-1, BHOPAL

ITA 199/IND/2020[2015-16]Status: DisposedITAT Indore29 Oct 2021AY 2015-16

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing

Section 115JSection 253Section 263

carry out hedging transaction of the foreign currency. A sum of Rs.118.32 crores is claimed as foreign exchange fluctuation expenditure which also includes “marked to market” loss of notional nature at Rs.2,82,42,778/-. Both the lower authorities have allowed the claim of foreign exchange fluctuation expenditure except for the notional loss of Rs.2

M/S ISOFT HEALTH MANAGEMENT (INDIA) PVT. LTD.,,CHENNAI vs. DCIT, BANGALORE

In the result, appeal of assessee is allowed

ITA 1210/BANG/2011[2007-08]Status: DisposedITAT Indore21 Aug 2023AY 2007-08

Showing 1–20 of 79 · Page 1 of 4

Deduction30
Section 26321
Reopening of Assessment17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputer Sciences Dcit, Circle 11(4) Corporation India Private No. 14/3, 5Th Floor, R.P. Limited Bhawan Nrupathunga (Formerly Isoft Health Road Vs. Management (India) Pvt. Bangalore Ltd.) Unit-13, Block-2, Sdf Building Mpez Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaco 2465N Assessee By Shri Vishal Kalra, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 03.08.2023 Date Of Pronouncement 21.08.2023

Section 143(3)Section 144C(13)Section 144C(15)(b)Section 144C(5)Section 153(1)Section 92C

loss to find any merit in the contention raised on behalf of the Department. Para 3.7 of the Instruction clearly states that: "For administering the transfer pricing regime in an efficient manner, it is clarified that though the AO has the power u/s. 92C to determine the ALP of an international transaction or specified domestic transaction, determination of ALP should

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

forwarded the said letter to the AO for information. Considering the fact that the appellant has suffered losses on trades on NMCE through brokers S. N. Commodities and Shubhlaxmi Commodities the appellant was required to file confirmed copy of accounts from both the brokers and to explain as to why the loss should not be disallowed. The submission filed

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

forwarded the said letter to the AO for information. Considering the fact that the appellant has suffered losses on trades on NMCE through brokers S. N. Commodities and Shubhlaxmi Commodities the appellant was required to file confirmed copy of accounts from both the brokers and to explain as to why the loss should not be disallowed. The submission filed

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

forwarded the said letter to the AO for information. Considering the fact that the appellant has suffered losses on trades on NMCE through brokers S. N. Commodities and Shubhlaxmi Commodities the appellant was required to file confirmed copy of accounts from both the brokers and to explain as to why the loss should not be disallowed. The submission filed

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)

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

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)

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

ACIT CENTTRAL -2 INDORE, INDORE vs. M/S KALYAN TOLL INFRASTRUCTURE LTD, INDORE

Accordingly ground no. 2 of the cross objection stands allowed

ITA 13/IND/2021[2013-14]Status: DisposedITAT Indore11 Mar 2022AY 2013-14

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year:2013-14 Dcit Central-2, M/S Kalyan Toll Infrastructure Indore Ltd., Indore बनाम/ (Appellant) (Respondent ) Vs. P.A. No.Aacck1840M

Section 132Section 139Section 153ASection 68

price of allotment was determined on the basis of valuation exercise carried out by the appellant as prescribed by the relevant rules of the Income Tax Act and also the Companies Act, which has also not been disputed by the AO. The appellant has submitted that considering its business model, revenues and profits generated in the past and also

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

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)

loss account an amount of Rs. 19,67,06,774/- is debited under the head City Environmental Development and Preservation Expenses. It was contended by the assessee before the Ld. AO that these expenses are done for the development of the City Environmental Development and Preservation on the direction of the State Government and thus these are part

THE ACIT 4(1), INDORE vs. M/S SUYASH EXIM P LTD , INDORE

Accordingly, departmental grounds with regard to addition of Rs.1,81,847/- are dismissed

ITA 356/IND/2020[2011-12]Status: DisposedITAT Indore19 Jan 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Manish Borad(Virtual Hearing) Assessment Year: 2011-12

Section 147

carried out by the Govt. Investigation Agency whereas it was proved in respect of several angle that the assessee allowed a synchronized commodity trading and misused NMCE platform. 5) On the facts and in the circumstances of the case, the ld. CIT(A) was not justified in not considering that the Assessing Officer had sufficient reason to believe to reopen

ASSISTANT COMMISSIONER OF INCOME TAX, INDORE vs. COMMANDER INDUSTRIES PRIVATE LIMITED, INDORE

In the result, the appeal of the revenue and CO of assessee are dismissed

ITA 24/IND/2024[2020-21]Status: DisposedITAT Indore25 Oct 2024AY 2020-21
Section 139(1)Section 142(1)Section 143(2)Section 32(1)Section 43(1)Section 43(6)(c)Section 47

carrying with it the benefit of the business.\"\nThe Court had further explained that:\n\"A variety of elements goes into its making, and its composition varies in different trades and in different businesses in the same trade, and while one element may preponderate in one business, another may dominate in another business. And yet, because of its intangible nature

ACIT CENTRAL-2 INDORE, INDORE vs. SHRI .GAURAV TEKRIWAL, INDORE

In the result, this appeal of Revenue is dismissed

ITA 62/IND/2021[2015-16]Status: DisposedITAT Indore21 Nov 2022AY 2015-16

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Acit, Central -2 Shri Gaurav Tekriwal Indore बनाम/ 204, Princess Valley, South Tukoganj, Indore Vs. (Appellant / Revenue) (Respondent / Revenue) Pan: Acppt 1628 Q Assessee By Shri Anil Kamal Garg, Arpit Gaur, Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 21.09.2022 Date Of Pronouncement 21.11.2022

Section 143(2)Section 143(3)Section 2Section 54FSection 55(2)(a)Section 57

carried forward as such as closing balance on 31.03.2015. Thus, the evidences placed by the assessee clearly demonstrate that no transaction had been done. During hearing, Ld. DR is not able to controvert these submissions of assessee. In this view of matter, we are inclined to agree with Ld. CIT(A) that the assessee has not done any transaction