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7 results for “capital gains”+ TP Methodclear

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Key Topics

Section 2608Section 260A5Comparables/TP3Section 2542Section 2(22)(e)2Section 482Capital Gains2

THE PR COMMISSIONER OF INCOME TAX vs. SMT SAROJINI M KUSHE

Appeal stands dismissed

ITA/475/2016HC Karnataka01 Dec 2021

Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR

Section 260Section 260ASection 48Section 50CSection 50D

method to arrive at the full market value of consideration. 14. In Seshasayee Steels [P.] Ltd., V/s. Assistant Commissioner of Income Tax, Company Circle VI[2], Chennai [(2020) 115 taxmann.com 5 (SC)] while considering the provision of Section 53 of the TP Act in the context of capital gains

PR COMMISSIONER OF WEALTH TAX-6 vs. M R KODANDRAM

Appeals stand dismissed

WTA/11/2017HC Karnataka18 Oct 2019

Bench: RAVI MALIMATH,ASHOK S.KINAGI

Section 260Section 260A

method to arrive at the full market value of consideration. 16. In Seshasayee Steels [P.] Ltd., V/s. Assistant Commissioner of Income Tax, Company Circle VI[2], Chennai [(2020) 115 taxmann.com 5 (SC)] while considering the provision of Section 53 of the TP Act in the context of capital gains

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/512/2017HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 2(22)(e)Section 254Section 260

TP)A No.461/Bang/2016 (Annexure F), to the extent questioned herein; in the interest of justice & equity etc. This I.T.A. having been heard and reserved on 12-07-2018, coming on for Pronouncement of Judgment, this day, Dr Vineet Kothari, J, delivered the following: J U D G M E N T Mr. Percy Pardiwala. Sr. Counsel a/w Mrs. Tanmayee Rajkumar

THE PR COMMISSIONER OF INCOME TAX vs. M/S INTEVA PRODUCTS

ITA/395/2017HC Karnataka07 Aug 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

method for determination of ALP with regard to the manufacturing segment and has accepted same comparable as selected by assessee for bench marking analysis? 2. Whether on the facts and in the circumstances of the case, the Tribunal is right in directed the AO/TPO to compute operating margin of the assessee as well as companies including forex gain/loss to foreign

PR COMMISSIONER OF INCOME TAX-5 vs. M/S IGEFI SOFTWARE

ITA/69/2016HC Karnataka26 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260Section 260A

method by which the AO had worked out the PLI of 12.7% for the assessee has been reproduced at para 08 above. Whole of the revenue of assessee was from software development services rendered to its AE, in Mauritius. Assessee in its TP study had adopted TNMM for justifying its international transactions and selected nine comparable companies and after making

THE PR. COMMISSIONER OF INCOME TAX vs. M/S INDIGRA EXPORTS P LTD

ITA/322/2016HC Karnataka30 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

TP]A No.193/Bang/2015 dated 10.11.2015, relating to the Assessment Year 2010-11. 2. The appeal has been admitted on 27.04.2018 to consider the following substantial questions of law: Date of Judgment 30-07-2018, ITA No.322/2016 The Pr. Commissioner of Income-tax & Another Vs. M/s. Indigra Exports P. Ltd., 3/9 “1. Whether on the facts and circumstances of the case

THE PR.COMMISSIONER OF INCOME TAX vs. M/S E4E BUSINESS SOLUTIONS INDIA PVT LTD

ITA/352/2016HC Karnataka26 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260Section 260A

TP)A No.1845/Bang/2013 for the A.Y.2009-10. Date of Judgment 26-07-2018 I.T.A.No.352/2016 The Pr. Commissioner of Income-Tax & Anr., Vs. M/s. E4E Business Solutions India Pvt., Ltd., 3/17 2. This appeal has been ADMITTED on 06.12.2017 to consider the following substantial questions of law as formulated in the appeal memo: “1. Whether on the facts