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382 results for “transfer pricing”+ Section 23(1)(c)clear

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Key Topics

Addition to Income49Section 26034Section 1928Section 1487Section 1946Section 194J5Section 405Section 260A5Section 143(3)4

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 PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144C

Showing 1–20 of 382 · Page 1 of 20

...
Deduction4
TDS4
Disallowance4
Section 144C(13)
Section 260A
Section 37(1)
Section 92A
Section 92C

Transfer Pricing Officer and subsequently an order under Section 92CA came to be passed on 23.01.2013 making the following adjustment to the admitted value of international transactions. 5 (a) In respect of sale of iron ore 111,48,68,440/- (b) In respect of Helicopter Hiring Charges 72,23,641/- Total adjustments Rs.112,20,92,081/- 7. It is further

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

Transfer Pricing Officer” means a Joint Commissioner or Deputy 23 Commissioner or Assistant Commissioner authorized by the Board to perform all or any of the functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons. 144C. (1) xxxxx (2) xxxxx (b) file his objections, if any, to such variation with

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 u/s 143(1

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 u/s 143(1

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

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

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

23. Sub-section (3) of Section 92C provides that the AO can proceed to determine the ALP only in cases he is of the opinion on the basis of material that (a) the price charged or paid in international transaction, has not been determined in accordance with sub-sections (1) and (2) of Section 92-C; or b) that information

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

WP/15230/2022HC Karnataka17 Oct 2022

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

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

23 D were arrested by the NCB for involvement in drug business. 3.4. The Narcotics Control Bureau, Bengaluru registered a case vide F.No. 48/1/ 14/2020/BZU dated 22.08.2020 u/s 22, 27A, 28 and 29 of NDPS Act, 1985 against Mr. Mohammed Anoop and others. 3.5. Offences under Section 22 & 27A of Narcotics Drugs and Psychotropic Substances Act, 1985 are scheduled offences

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

23 acquitted, that by itself cannot be the basis to acquit the co-accused who is charged under Section 109 of I.P.C. Though such a view may be generally correct, there are exceptions to that Rule. It is argued that in the present case nothing has been brought on record by the Applicant to show that the prosecution case against

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 COMMR OF INCOME TAX vs. NIKE INC

Appeals are dismissed

ITA/976/2008HC Karnataka07 Mar 2013

Bench: B.MANOHAR,N.KUMAR

Section 260A

price, quality, quantity, to whom to be shipped and billed. The local manufacturer in India is conveyed of the decision by the office in USA and once it is accepted, the local manufacturer carries on his activity. The liaison office keeps a close watch on the progress, quality, etc., at the manufacturing workshop. The liaison office also keeps a watch

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

In the result, the appeals are partly allowed

ITA/133/2007HC Karnataka23 Aug 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 260

price of transfer for the purpose of computation of deduction u/s.80HH and 80I of the Act? A-10. Whether the Tribunal was correct in holding that excise duty and sales tax should not be included in the total turnover for the purpose of computation of deduction u/s.80HHC of the Act? 6. In all the three appeals, the following question

SRI M MADHAVA GOWDA vs. UNDER SECRETARY TO GOVERNMENT

WP/27825/2014HC Karnataka30 Sept 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

price of the liquor being sold to the customers depending upon the varying degree of facilities provided by them to the customers. 28. The Legislature has inserted Entry 59A in the III Schedule to KVAT Act and has chosen to provide for levy of tax on liquor sold by certain licence holders. Notification – II bearing No.FD 21 CSL 2014 dated

FEDERATION OF WINES MERCHANTS ASSOCIATION vs. THE STATE OF KARNATAKA

WP/13078/2014HC Karnataka30 Sept 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

price of the liquor being sold to the customers depending upon the varying degree of facilities provided by them to the customers. 28. The Legislature has inserted Entry 59A in the III Schedule to KVAT Act and has chosen to provide for levy of tax on liquor sold by certain licence holders. Notification – II bearing No.FD 21 CSL 2014 dated

M. NARAYANAPPA vs. THE STATE OF KARNATAKA

WP/14620/2014HC Karnataka30 Sept 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

price of the liquor being sold to the customers depending upon the varying degree of facilities provided by them to the customers. 28. The Legislature has inserted Entry 59A in the III Schedule to KVAT Act and has chosen to provide for levy of tax on liquor sold by certain licence holders. Notification – II bearing No.FD 21 CSL 2014 dated

G RAMACHAR vs. THE STATE OF KARNATAKA

WP/18939/2009HC Karnataka18 Mar 2016

Bench: ABHAY SHREENIWAS OKA (CJ),B.V.NAGARATHNA

Section 22A

price of the said property); -: 13 :- 3) Section-131(C) of Karnataka Land Revenue Act, 1964; read with Rule-46(H) of Karnataka Land Revenue Rules, (to issue survey sketch or land survey map as per prescribed Form-11-E); 4) Sec. 81-A of Karnataka Land Reforms Act, 1961 (to declare in the prescribed format by the purchaser

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

C (5) of the Income Tax Act, 1961, the Assessee Company preferred an appeal before the learned Income Tax Appellate Tribunal (ITAT), who disposed of the said appeal by the impugned Order dated 22/02/2017. 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. 7/86 9. The learned