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9 results for “transfer pricing”+ Deemed Dividendclear

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Key Topics

Section 26018Section 14A11Section 260A5Disallowance4Section 403Deduction3Addition to Income3Section 2542Section 2(22)(e)2

PR COMMISSIONER OF INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

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

ITA/271/2017HC Karnataka16 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 14ASection 260Section 260ASection 40Section 9

DEEMED FIT, IN THE INTEREST OF JUSTICE. THIS I.T.A. COMING ON FOR HEARING, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: JUDGMENT This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the revenue. The subject matter of the appeal pertains to the Assessment year

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

Section 10A2
ITA/107/2025
HC Karnataka
12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

deemed to be the arm's length price :] Provided also that where more than one price is determined by the most appropriate method, the arm's length - 16 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 price in relation to an international transaction or specified domestic transaction undertaken

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

deemed to be dividend in terms of section 2(22)(e) of the Act, although the said provision would not be applicable? 5. We re-formulate the substantial question of law which we propose to answer and on which the arguments were heard by us, in the following manner:- “Whether the Income Tax Appellate Tribunal has power under Section

THE PR. COMMISSIONER OF INCOME TAX (4) vs. M/S CHAMUNDI WINERY AND DISTILLERY

ITA/172/2017HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

dividend which his wife received could not be deemed to be his income under section 16(1)(c) and that in his case section 16(3) did not apply, because there was no transfer of the shares to his wife. … … … … … … Date of Judgment 25-09-2018 I.T.A.No.155/2016 and connected matters The Pr. Commissioner of Income

PR. COMMISSIONER OF INCOME TAX vs. M/S CHAMUNDI WINERY AND DISTILLERY

ITA/467/2015HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

dividend which his wife received could not be deemed to be his income under section 16(1)(c) and that in his case section 16(3) did not apply, because there was no transfer of the shares to his wife. … … … … … … Date of Judgment 25-09-2018 I.T.A.No.155/2016 and connected matters The Pr. Commissioner of Income

M/S CANARA BANK BSCA SECTION vs. THE ASST COMMISSIONER OF INCOME TAX CIRCLE-11(2)

ITA/1397/2006HC Karnataka12 Nov 2013

Bench: N.KUMAR,RATHNAKALA

Section 143Section 260

dividends and interest for which the assessee has to incur any expenditure. This is the consequence of computerization, online transaction through NEFT[National Electronic Fund Transfer], RTGS [Real Time Gross Settlement] and also DEMAT Accounts. The assessing authority should take note of these developments in deciding whether any expenditure is incurred in earning the said income. The discussion

COMMISSIONER OF INCOME TAX vs. SRI.M.R.JANAKIRAM (HUF)

The appeal is allowed

WTA/19/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 449Section 456Section 456(1)Section 456(2)Section 483

deemed to be in the custody of the Tribunal as from the date of the order for the winding up of the company". Accordingly, the official liquidator had taken possession of the company's land ad measuring 176 acres, buildings, plants and machineries, fixtures and movable assets, residential quarters and sites etc., situated at Yantrapura, Harihara, Davangere District. Subsequently with

THE PR COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S DELHI INTERNATIONAL AIRPORT PVT LTD

In the result, we don to find any

ITA/352/2018HC Karnataka25 May 2021

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

Section 14ASection 260A

transfer of the commodity or scripts: Provided that for the purposes of this clause — (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

ITA/133/2015HC Karnataka15 Feb 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(1)Section 14ASection 260Section 73

transfer of the commodity or scripts: Provided that for the purposes of this clause — (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured