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7 results for “disallowance”+ Section 92C(3)clear

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Key Topics

Section 26010Disallowance6Transfer Pricing5Section 92C4Section 10A4Deduction4Addition to Income4Section 260A3Section 143(3)3Section 40

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

3) of Section 92C are attracted. It follows that sub-section (4) of Section 92C is not attracted. 25. More importantly, the proviso to sub-section (4) of Section 92C also clearly states that no deduction under Section 10A or 10AA or 10B or under Chapter VI-A of the Act would be allowed in respect of the amount

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

3
Section 80J2
Section 14A2
Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

Disallowance of Expenses under Explanation to section 37(1) and in respect of third issue i.e., addition made on account of sale of Land, the ITAT set-aside the order of CIT (A) on that issue and restored the matter to A.O. for a fresh decision with the same directions as were given by the tribunal

SKF TECHNOLOGIES (INDIA) P. LTD., vs. DEPUTY COMMISSIONER OF INCOME TAX

The Appeal is disposed of

ITA/83/2017HC Karnataka19 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260Section 40Section 92C

3. The issue involved before the learned Tribunal was to benchmarking of the value of the group IT expenses shared by the Assessee-Company and paid to its Associate Enterprise M/s. SKF Data Services, Sweden, where the adjustments were made under Section 92C of the Act required further investigation and therefore the learned Tribunal remanded the matter back

PR COMMISSIONER OF INCOME TAX-5 vs. M/S PAGE INDUSTRIES LTD

In the result, the appeal fails and is hereby dismissed

ITA/285/2017HC Karnataka08 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(2)Section 14ASection 260Section 80JSection 92C

3) of the Act. The Transfer Pricing Officer treated the expenditure incurred on the advertisement and marketing and product promotion as an international transaction and determined the arms length price by applying bright line method. Pursuant to the order passed by the Transfer Pricing Officer, a draft assessment order was passed by the Assessing Officer, by which disallowance

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

In the result, we do not find any merit in this

ITA/680/2015HC Karnataka15 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 10ASection 143(3)Section 260Section 260ASection 80H

3) of the Act assessed the income at Rs.33,98,72,603/- after making disallowances with regard to addition on account of income from other sources, addition on account of foreign exchange loss and addition on account of Arms 6 Length Price (ALP). 5. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals

PR COMMISSIONER OF vs. M/S LUWA INDIA PRIVATE LIMITED

ITA/296/2017HC Karnataka29 Jun 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 148Section 260

3) of the Act, can only determine the Arms Length Price of an international transaction, is no longer res integra and the same has already been adjudicated by the decisions of Delhi and Bombay High Courts respectively in 'CIT Vs. EKL APPLIANCES LTD.' and 'CIT Vs. LEVER INDIA EXPORTS LTD', supra. The aforesaid issue is no longer res integra

PR COMMISSIONER OF vs. M/S TELELOGIC INDIA PVT LTD

ITA/550/2016HC Karnataka28 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260

disallowance of rent equalization provision for an amount of Rs.5,47,46,191/- even when the assessing authority has applied Accounting Standard -19 of principle of accountancy, which stipulated that if no liability were to exist against a provision, the Date of Judgment 28-06-2018, ITA No.550/2016 Pr. Commissioner of Income Tax-7 & another Vs. M/s Telelogic India