BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

265 results for “transfer pricing”+ Section 153(3)clear

Sorted by relevance

Delhi1,080Mumbai760Karnataka265Bangalore205Hyderabad180Chennai170Jaipur152Chandigarh143Ahmedabad107Cochin83Indore75Kolkata67Pune49Lucknow28Surat22Guwahati19Rajkot19Raipur19Calcutta17Dehradun15SC13Amritsar13Nagpur12Jodhpur5Visakhapatnam4Telangana4Allahabad3Rajasthan3Cuttack2Panaji1Andhra Pradesh1Ranchi1Agra1

Key Topics

Addition to Income55Section 26023Section 14811Section 92C6Section 1476Section 143(2)5Section 143(3)4Section 144C(13)3Section 4

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

section (254, 263,264 orders) Post 01.04.2019, If the order is received after 01.04.2019, then in such cases the time limit has been increased to 12 months 153(4) Notwithstandi ng sub-sec, (1), (2) & (3), where a reference has been made to Transfer Pricing

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

Showing 1–20 of 265 · Page 1 of 14

...
3
Transfer Pricing3
Limitation/Time-bar2
WP/11618/2016
HC Karnataka
27 Sept 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Section 142(4)Section 143(2)Section 143(3)Section 144Section 144CSection 263Section 92C

Transfer Pricing Officer before the said date, or a reference under sub-section (1) is made on or after the 1st day of June, 2007, an order under sub- section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY INDIA PVT LTD

In the result, we do not find

ITA/307/2018HC Karnataka06 Apr 2021

Bench: ALOK ARADHE,M.G.S. KAMAL

Section 143(2)Section 153(1)(a)Section 153(3)(ii)Section 260Section 260ASection 92C

3. The Transfer Pricing Officer by an order dated 13.06.2012 after affording an opportunity to the assessee passed an draft order of assessment on 05.07.2012 and forwarded the same to the assessee on 11.07.2012. The assessee filed an objection before the Dispute Resolution Panel on 09.08.2012. Thereafter, the Dispute Resolution Panel passed an order on 22.04.2013. The Assessing Officer passed

M/S T T K PRESTIGE LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WP/30388/2015HC Karnataka10 Aug 2018

Bench: The Hon’Ble Mrs.Justice S.Sujatha

Section 143Section 147Section 148

TRANSFER PRICING OFFICER AND ANOTHER’ [(2010) 320 ITR 565 [DELHI]. [e] ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS vs. ICICI SECURITIES PRIMARY DEALERSHIP LTD. [2012] 348 ITR 299 (SC) [f] ‘COMMISSIONER OF INCOME TAX vs. I.A.E.C. (PUMPS) LTD.,’ [(1998) 150 CTR SC 126 - 14 - 6. Submissions of the learned Counsel for the Revenue: Learned Counsel Sri. K.V. Aravind appearing

PR COMMISSIONER OF INCOME TAX vs. M/S TATA POWER SOLAR SYSTEMS LIMITED

Appeals are dismissed at the stage of admission itself as being

ITA/527/2022HC Karnataka12 Aug 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 143(3)Section 144Section 144C(5)Section 260Section 92C

153(1) of the Act for passing an order under Section 143(3) of 7 Order dated 7.9.2020 passed in WP No.32699/2019 8 Judgment dated 31.3.2022 passed in WA No.1120/2021 & c/w matters. - 7 - NC: 2024:KHC:32486-DB ITA No. 527 of 2022 C/W ITA No. 528 of 2022 the Act and held that the order under Section 143(3

THE PR.COMMISSIONER OF INCOME TAX vs. M/S. YOKOGAWA INDIA LTD

The appeal is dismissed

ITA/431/2022HC Karnataka26 Sept 2025

Bench: S.G.PANDIT,K. V. ARAVIND

Section 143(2)Section 143(3)Section 144C(13)Section 144C(4)Section 260Section 92C

153 [or section 153B], pass the assessment order under sub- section (3) within one month from the end of the month in which,- (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub- section (2), issue

M/S HIMALAYA DRUG COMPANY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, both the writ petitions are

ITA/571/2017HC Karnataka04 Jun 2025

Bench: This Court Under Section 260A Of The Income-Tax Act, 1961 (For Short “It Act”), Questioning The Order Dated 21.06.2017 In It(Tp)A No.807/Bang/2016 Passed By Income Tax Appellate Tribunal, “B” Bench, Bengaluru (For Short “Tribunal”), Dismissing The Appeal Refusing To Declare The Proceedings Under Section 144C Of The It Act As Null & Void.

Section 143(1)Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 260Section 260ASection 92C

3) of the Act. Against which, the appellant filed an appeal before the Tribunal. The Tribunal, under impugned order dated 21.06.2017 dismissed the appeal of the appellant. 5. Learned senior counsel Sri.Chythanya for appellant would contend that the final assessment order dated 18.02.2016 is contrary to Section 144C(13) of the IT Act. He invites attention of this Court

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

ITA/504/2013HC Karnataka01 Jul 2015

Bench: S.SUJATHA,VINEET SARAN

Section 143(1)Section 147Section 148Section 45(2)

153, assess or reassess such income and also any other income chargeable to tax, which has escaped assessment. Further Assessing Officer 21 may also assess or reassess such other income which has escaped assessment and which comes to his notice subsequently in the course of proceedings under this section. Assessing Officer is required to record the reasons for reopening

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

WP/13261/2020HC Karnataka16 Mar 2021

Bench: The Hon’Ble Mr. Justice Suraj Govindaraj Writ Petition No. 13261 Of 2020 (Gm-Res) Between: Mr. Bineesh Kodiyeri S/O Mr. Kodiyeri Balakrishnan Aged About 37 Years Kootamvilla Lane, Maruthankuzhi Thiruvananthapuram District Kerala State – 695013

Section 19Section 482

price of which exceeds on e crore rupees; or (d) Fraudulently availing of or attempt to avail of drawback or any exemption from duty provided under this Act, if the amount of drawback or exemption from duty exceeds fifty lakh rupees. WP No. 13261 of 2020 65 (7) Save as otherwise provided in sub-section (6), all other offences under

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

WP/21206/2014HC Karnataka25 Jun 2018

Bench: S.SUJATHA

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 149Section 152Section 92B(2)Section 92C

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of arm’s length price in respect of international transactions - 4 - reported by the petitioner during the subject Assessment year. TPO passed a detailed order under Section 92CA(3) of the Act accepting the arm’s length price reported by the petitioner in respect of its international transactions

THE PR.COMMISSIONER OF INCOME TAX vs. M/S SIGMA ALDRICH CHEMICALS PVT LTD

The appeal is disposed of with liberty as prayed for by the learned counsel for

ITA/47/2023HC Karnataka30 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 153Section 153(1)Section 260Section 92C

Transfer Pricing Officer in accordance within parameters set out in Section 92CA and within limitation period set out in Section 153 (1) of the Act? 3

SMT. M R PRABHAVATHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WTA/1/2019HC Karnataka04 Mar 2020

Bench: The Hon’Ble Mr. Justice K.Natarajan Election Petition No.1 Of 2019 Connected With Election Petition No.2 Of 2019

Section 81

Section 33A of RP Act and 106 he has committed corrupt practice of bribery as contemplated under Sections 123(1)(A), 123(1)(B), 123(7), 123(7)(b), 123(vii)(d), 123(7)(h) and Section 123(8), 123(3), 3A and 123(6) of R.P. Act ? The petitioner in E.P. No.2/2019 has contended that respondent No.1 committed corrupt

SMT. S. JALAJA vs. UNION OF INDIA

In the result, writ appeals are allowed

WA/1105/2019HC Karnataka24 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 4

3) the penalty, the State providing a maximum of $ 50 the Commonwealth Act prescribing a maximum of $ 100, or imprisonment, or both; (4) the tribunal itself". Starke, J. observed as follows:- "It is not difficult to see that the Federal Code would be 'disturbed or deranged' if the State Code applied a different sanction in respect of the same

THE PR COMMISSIONER OF INCOME TAX vs. M/S YOKOGAWA INDIA LTD

ITA/455/2022HC Karnataka25 Nov 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 144Section 144CSection 153Section 254Section 260

3. The Dispute Resolution Panel [DRP], in exercise of its jurisdiction under Section 144C[6] of the IT Act, has issued certain directions on 24.11.2015. The Transfer Pricing Officer [TPO] has communicated to the Assessing Officer that the DRP has directed the conduct of a fresh transfer pricing

THE PR. COMMISSIONER OF vs. M/S FLEXTRONICS TECHNOLOGIES

Appeal is dismissed

ITA/332/2019HC Karnataka09 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 144CSection 144C(10)Section 144C(13)Section 153(3)Section 260

153(3) of the Act? 4. Whether on the facts and in the circumstances of the case, the Tribunal is right in law in holding that assessment order passed under Section - 4 - ITA No.332/2019 143(3) read with Section 144C(13) is bad in law even though the said order is passed according to parameters set out in said provision

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

3 CIT Vs. Sitaldas Tirathdas 41 ITR 367 (SC) 12-16 4 CIT Vs. Pompie Tile Works 175 ITR 1 (Kar) 17-19A 5 CTI Vs. Dharma Productions (P) Ltd 153 ITR 105 (Bom) 20-27 6 Raja Bejoy Singh Dudhuria Vs. CIT 1 ITR 135 (Privy Council) 28-31 9 CIT Vs. Nagarbail Salt-Owners Co-Op Society

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

3 CIT Vs. Sitaldas Tirathdas 41 ITR 367 (SC) 12-16 4 CIT Vs. Pompie Tile Works 175 ITR 1 (Kar) 17-19A 5 CTI Vs. Dharma Productions (P) Ltd 153 ITR 105 (Bom) 20-27 6 Raja Bejoy Singh Dudhuria Vs. CIT 1 ITR 135 (Privy Council) 28-31 9 CIT Vs. Nagarbail Salt-Owners Co-Op Society

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed

THE PR. COMMISSIONER OF INCOME TAX CIT (A) vs. 24/7 CUSTOMER PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

ITA/153/2020HC Karnataka27 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 260

153 of 2020 ORAL JUDGMENT (PER: HON'BLE MR JUSTICE S.G.PANDIT) Heard the learned counsel Sri. Sushal Tiwari for the appellants/Revenue and Smt. Tanmayee Rajkumar, learned counsel for the respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 20.09.2019 passed