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265 results for “transfer pricing”+ Section 153(4)clear

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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

section 153, if the period of limitation available to the Transfer Pricing Officer for making an order is less than sixty days, such remaining period shall be deemed to have been extended accordingly.) (4

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

4 Section 92C of the Act on 11.01.2011. This court in W.P.No.45313/2011 by an order dated 08.12.2011 restrained the Transfer Pricing Officer from proceeding to pass a draft assessment order for a period upto 07.03.2012 i.e., approximately 3 months. The writ petition was disposed of by a bench of this court vide order dated 07.03.2012 remitted the matter

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

153 or section 153B, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received.” 10. In terms of the above provision, the Assessing Officer shall complete the assessment without providing any further opportunity of being heard to the assessee, within one month

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

4) The Assessing Officer shall, notwithstanding anything contained in section 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

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

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

transfer pricing adjustment was made, as also certain other additions on corporate tax issues were made. 4. Aggrieved by the draft assessment order, the assessee filed objections before the Dispute Resolution Panel6. In response to the objections, the DRP issued directions under Section 144C(5) of the Act on 30.12.2015, confirming the additions proposed in the draft assessment order

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

4. It is the contention of the petitioner that the very same issue came up for adjudication for the Assessment Year 2007-08. Submissions were made by the petitioner pertaining to this issue in terms of the letter dated 11.08.2009. The respondent, after considering the same, completed the assessment under section 143[3] of the Act for the Assessment Year

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. Learned counsel for the assessee submits that the tax effect in this appeal is less than Rs.2 Crores and therefore, the appeal should not be entertained at the instance of the revenue in view

R JANARDHANA BABU vs. THE MANAGING DIRECTOR

Accordingly, the writ petitions are allowed

WP/37528/2010HC Karnataka07 Jul 2017

Bench: The Hon’Ble Mr. Justice B. Veerappa

153. B Zseherpel, s/o Balaram Naidu, aged about 56 years, Working as pharma Assistant, Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road, Bangalore-560049 154. J Nandini, d/o Jayaram, aged about 56 years, Working as pharma Assistant, Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road, Bangalore-560049 155. Juliana S Samuel, d/o M A Doss, aged about

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

153 of the Income Tax Act, 1961 ['IT Act'] to complete the assessment in terms of Section 144 C(13) of the IT Act. This Court must advert to the indisputable facts before the rival submissions are considered. 3. The Dispute Resolution Panel [DRP], in exercise of its jurisdiction under Section 144C[6] of the IT Act, has issued certain

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

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

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

M/S INDUS TOWERS LTD vs. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES

In the result, we pass the following order:

WA/3403/2011HC Karnataka07 Sept 2011

Bench: RAVI MALIMATH,N.KUMAR

Section 4

Section 66 thereof created charge of service tax in regard to taxable services. Service Lax’ is defined in clause (34) of Set lion 65 to mean tax chargeable under the provLsioi is of that napler. 7’axable ceri’icc is dejrnea Iunder sub ‘‘larcsc’ Ib) 1 ½usc 4 1 [ 5j 0 n ° mc a an, srvkc provided tu. znrcr cilia

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

4) (1), PRESENT ADDRESS, DCIT, CIRCLE -2(1) (1), 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU-560095. …APPELLANTS (BY SRI. SUSHAL TIWARI, ADVOCATE) Digitally signed by BHARATHI S Location: HIGH COURT OF KARNATAKA - 2 - NC: 2024:KHC:40416-DB ITA No. 153 of 2020 AND: 24/7 CUSTOMER PVT. LTD., EMBASSY GOLF LINKS BUSINESS PARK, CHALLAGHATTA VILLAGE, VARTHUR HOBLI

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

THE COMMISSIONER OF INCOME - TAX vs. M/S BIOCON LTD.,

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

ITA/653/2013HC Karnataka11 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 260Section 260ASection 37

transferred to the trust at the face value and the employees of the assessee were allowed to exercise the option to buy the shares within the time prescribed under the scheme subject to terms and conditions mentioned therein. The assessee claimed the difference of market price and allotment price as a discount and claimed the same as an expenditure under