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396 results for “transfer pricing”+ Section 2(22)(e)clear

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Key Topics

Addition to Income48Section 26040Section 14810Section 1928Section 1946Section 1476Section 14A6Section 356Section 260A5

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

price of shares of the Assessee - Indian Company, would certainly fall within the ambit of Section 2(22)(e) of the Act and could be taxed as Dividends, in the hands of the Assessee Company. Date of Judgment :23-07-2018 I.T.A.No.512/2017 M/s. Fidelity Business Services India Pvt. Ltd., Vs. Assistant Commissioner of Income-Tax, & Anr. 9/86

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Showing 1–20 of 396 · Page 1 of 20

...
Deduction5
Transfer Pricing3
Disallowance3
Section 143(3)
Section 144C
Section 144C(13)
Section 260A
Section 37(1)
Section 92A
Section 92C

e-filed its return of income for the assessment year 2009-10 declaring an income of Rs.486,38,96,690/-. The case was selected for scrutiny and the assessment was completed under Section 143(3) read 3 with Section 144C(13) of the Income Tax Act on 31.12.2013, determining total income at Rs.10,86,34,35,052/- by making various

SHRI. PARSWANATH vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/304/2019HC Karnataka13 Sept 2021

Bench: The Hon'Ble Mr. Justice M. Nagaprasanna

Section 109Section 13(1)(e)Section 13(2)Section 397Section 482

22 proceeding against the petitioner under the Special Courts Act, 1979. 10. Hence, this CRLMP filed under Articles 226 and 227 of the Constitution of India challenging the impugned order dated 09-08-2018 passed by the learned Special Judge, Special Court, Cuttack in T.R.Case No.15 of 2018 is dismissed being devoid of any merit.” The Division Bench of High

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

WP/11618/2016HC Karnataka27 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

E 5 Equity Shares respectively and in terms of the investors amount of inflow read with the number of shares and the face value of share was Rs.10/- and the same were issued at premium of Rs.1,14,015/- during the relevant year read with previous year, the shares have been issued at premium of Rs.21,445.82/-, Rs.25

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

2) An appeal may lie under this section from an appellate decree passed ex- parte. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 35/80 (3) In an appeal under this section, the memorandum of appeal shall precisely state the substantial question of law involved

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

2) An appeal may lie under this section from an appellate decree passed ex- parte. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 35/80 (3) In an appeal under this section, the memorandum of appeal shall precisely state the substantial question of law involved

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)

E Sanmathi Indrakumar, Adv.) Appeal is filed under S.260 A of the Income Tax Act, 1961 praying to set aside the order passed by the ITAT, Bangalore in ITA 970/Bang/2009 on 26.04.2010, etc. ® 2 Appeal having been reserved on 20th April, 2015, coming on for pronouncement of Orders this day, Vineet Saran J, delivered the following: JUDGMENT The primary question

HEWLETT PACKARD FINANCIAL SERVICES INDIA PRIVATE vs. THE STATE OF KARNATAKA

STRP/412/2015HC Karnataka19 Feb 2016

Bench: S.SUJATHA,JAYANT PATEL

Section 23(1)Section 39(1)Section 5(2)Section 65(1)

transferred to the appellant and till then the rights over the goods wrests with the end customer only. In-fact in the MLA as pointed out by the FAA and AA, the description of leased equipments are not forthcoming and the appellant is not aware of the goods to be leased till the purchase order is placed

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

Transfer Pricing Officer during the proceeding for assessment, reassessment made. The period as specified in sub- section (1)(2) & (3) shall be further extended by 12 months. 153(5) To give effect to the order of the higher authorities i.e. CIT (A), ITAT, HC and SC orders To give effect to an order passed by higher authorities other than those

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

ITA/331/2007HC Karnataka27 Nov 2013

Bench: N.KUMAR,RATHNAKALA

Section 143(3)Section 147Section 148Section 2Section 260Section 45Section 45(4)

E N T THE HON’BLE MR. JUSTICE N. KUMAR A N D THE HON’BLE MRS. JUSTICE RATHNAKALA INCOME TAX APPEAL NO.331 OF 2007 BETWEEN: 1.THE COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE, C.R. BUILDING, QUEENS ROAD, BANGALORE. 2.THE ASSISTANT COMMISSIONER OF INCOME TAX WARD – 12(2), C.R. BUILDING, QUEENS ROAD, BANGALORE. ... APPELLANTS. (BY SRI K V ARAVIND

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

e) transactional net margin method; (f) such other method as may be prescribed by the Board. (2) The most appropriate method referred to in sub- section (1) shall be applied for determination of arm's length price, in the manner as may be prescribed: Provided that where more than one price is determined by the most appropriate method

M/S J K CEMENT WORKS vs. THE STATE OF KARNATAKA

STRP/100001/2014HC Karnataka23 Mar 2017

Bench: H.B.PRABHAKARA SASTRY,VINEET KOTHARI

Section 63Section 65Section 65(1)

E R Mr.V.R.Desai, Mr.Atul K.Alur, Mr.N.P.Vivek Mehta & Mrs.J.Tejavathi Advocates for petitioner. Mr.M.Kumar, Addl.Govt. Advocate for respondent. 1. The petitioner assessee, M/s.J.K.Cement Works, Muddapur, Mudhol Taluk, Bagalkot District, Karnataka, has filed these Revision Petitions under Section 65 of the Karnataka Value Added Tax Act, 2003 (for short ‘KVAT Act’) raising a question of law for consideration by this Court, being aggrieved

THE COMMISSIONER OF INCOME TAX vs. PRAVEEN V DODDANAVAR

ITA/100003/2014HC Karnataka20 Feb 2017

Bench: SREENIVAS HARISH KUMAR,VINEET KOTHARI

Section 63Section 65Section 65(1)

E R Mr.V.R.Desai, Mr.Atul K.Alur, Mr.N.P.Vivek Mehta & Mrs.J.Tejavathi Advocates for petitioner. Mr.M.Kumar, Addl.Govt. Advocate for respondent. 1. The petitioner assessee, M/s.J.K.Cement Works, Muddapur, Mudhol Taluk, Bagalkot District, Karnataka, has filed these Revision Petitions under Section 65 of the Karnataka Value Added Tax Act, 2003 (for short ‘KVAT Act’) raising a question of law for consideration by this Court, being aggrieved

THE BAILHONGAL URBAN COOPERATIVE BANK LTD vs. THE COMMISSIONER OF INCOME TAX

ITA/100001/2014HC Karnataka16 Dec 2015

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

Section 63Section 65Section 65(1)

E R Mr.V.R.Desai, Mr.Atul K.Alur, Mr.N.P.Vivek Mehta & Mrs.J.Tejavathi Advocates for petitioner. Mr.M.Kumar, Addl.Govt. Advocate for respondent. 1. The petitioner assessee, M/s.J.K.Cement Works, Muddapur, Mudhol Taluk, Bagalkot District, Karnataka, has filed these Revision Petitions under Section 65 of the Karnataka Value Added Tax Act, 2003 (for short ‘KVAT Act’) raising a question of law for consideration by this Court, being aggrieved

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

22 - 10. The assessee-company filed its return of income for the assessment year 2004-05 on 31.10.2004 disclosing a total income of Rs.134,86,47,530/- after claiming deduction u/s 10A of the Act to the extent of Rs.881,34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the Transfer Pricing

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

22 - 10. The assessee-company filed its return of income for the assessment year 2004-05 on 31.10.2004 disclosing a total income of Rs.134,86,47,530/- after claiming deduction u/s 10A of the Act to the extent of Rs.881,34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the Transfer Pricing

THE PR. COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICES PVT LTD

ITA/29/2019HC Karnataka10 Jun 2021

Bench: The Hon'Ble Mr. Justice V. Srishananda Civil Revision Petition No.29/2019 Between

Section 115Section 37(2)

22 Committee to terminate the contract after deciding that the contract was executed in breach of the undertaking given in clause 29 of the contract. These are allegations which will have to be established in a proper forum on the basis of the oral and documentary evidence, produced by the parties, in support of their respective claims. The objection taken

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

E N T ITA No.11/2017 is filed by the Revenue under Section 260A of the Income Tax Act, 1961 (‘Act’ for short) challenging the order dated 18.03.2016 passed by the Income Tax Appellate Tribunal, Bangalore Bench “B”, Bengaluru (‘Tribunal’ for short) in ITA No.35/Bang/2015 relating to the Assessment Year 2010-11. 2. The respondent – assessee (ITA No.11/2017) was the owner

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

E R These writ petitions are filed by the erstwhile employees of pharmaceutical company called Glaxosmithkline Pharmaceuticals Limited, a multinational company registered under the Companies Act against the common award dated 20th May 2010 made in I.D.No.36/2004 and connected cases on the file of the Presiding Officer, II Addl. Labour Court, Bengaluru, dismissing the petitions filed under Section

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

E N T This appeal is filed by the Revenue under Section 260A of the Income Tax Act, 1961 (‘Act’ for short) challenging the order dated 27.04.2016 passed by the Income Tax Appellate Tribunal, Bangalore Bench “A”, Bengaluru (‘Tribunal’ for short) in ITA No.989/Bang/2014 relating to the Assessment Year 2011-12. 2. This appeal was admitted by this Court