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3 results for “transfer pricing”+ Section 10Aclear

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Key Topics

Section 10A6Section 143(3)5Section 144C(5)3Section 92C3Section 143(2)2Exemption2Addition to Income2Transfer Pricing2

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

10A read with sub-section (1) to Section 92C, therefore, does not bar or prohibit clubbing of closely connected or intertwined or continuous transactions. This is discernible also from sub-rule (2) to Rule 10B quoted above. The sub-rule refers to ‘services provided', ‘functions performed', ‘contractual terms (whether or not such terms are formal or in writing

M/S ANDRITZ HYDRO PRIVATE LIMITED,BHOPAL vs. THE DCIT CIRCLE 1(1), BHOPAL

In the result, appeal of assessee is allowed for statistical purpose

ITA 75/IND/2022[2017-18]Status: DisposedITAT Indore28 Aug 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Andritz Hydro Private Dcit Circe 1(1) Ltd. Bhopal Vs. D-17, Mpakvn Industrial Area, Mandideep Raisen (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcv 2466 R Assessee By Shri Rahul, Kaul Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 28.08.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)

10A(d). The income tax rules permits the aggregation and clubbing of close related transactions as it is also supported by the OECD guidelines on transfer pricing. In order to examine whether number of transactions are closely linked or continuous so as to aggregate for the purpose of determining of arm’s length price it is to be seen that

THE ACIT, CENTRAL-2, INDORE vs. M/S. SHAKTI PUMPS (INDIA) LTD., INDORE

ITA 1358/IND/2016[2010-11]Status: DisposedITAT Indore26 Apr 2023AY 2010-11

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2010-11 Acit (Central)-2, Shakti Pumps (India) Ltd. Indore 226, Shastri Market, बनाम/ M.G. Road, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Aaecs 5027 L Revenue By Shri P.K. Mishra, Cit-Dr Assessee By Ms. Nisha Lahoti & Vijay Bansal, Ars Date Of Hearing 23/11/2022 / 22.02.2023 Date Of Pronouncement 26.04.2023

Section 10ASection 143(2)Section 143(3)Section 145Section 263

10A Rs.70089407/- after reallocation of expenses the exempted income has reduced by Rs.41793546/- and remained of Rs.28295861/-The reallocated expenses have reduced from the expenses of DTA unit. Therefore, taxable income has increased by Rs.41793546/-.” 2.26 It has been submitted by the appellant that it had correctly claimed deduction u/s 10AA in accordance with the provisions of section 10AA