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74 results for “transfer pricing”+ Section 260Aclear

Sorted by relevance

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Key Topics

Section 26085Section 260A79Section 10A33Comparables/TP32Deduction23Transfer Pricing18Disallowance13Section 10B12Addition to Income12Section 143(3)

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

Transfer Pricing Officer is correct or not has not been addressed. Therefore, for Assessment Year 2008-09 the proceedings are incomplete. 41. It is further contended by the learned counsel for the respondent / assessee that this appeal under Section 260A

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Showing 1–20 of 74 · Page 1 of 4

11
Section 92C10
Section 14A8
ITA/536/2015
HC Karnataka
25 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

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

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 and void. 2. The appeal coming on for admission

PRINCIPAL COMMISSIONER OF INCOME TAX - 6 vs. M/S. SAMSUNG R & D INSTITUTE BANGALORE PVT LTD

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

ITA/622/2017HC Karnataka30 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 260Section 260ASection 92

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 2009-10. The appeal was admitted by a bench of this Court vide order dated 08.04.2019 on the following substantial question of law: (i) Whether

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

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 2010-11. The appeal was admitted by a bench of this Court vide order dated 09.11.2018 on the following substantial questions of law: "(1) Whether on the facts

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

260A of the Income Tax Act, 1961 [the Act], impugning a common order dated 08.11.2024 [impugned order], passed by the learned Income Tax Appellate Tribunal [Tribunal] in ITA No.1367/Bang/2024 in respect of the Assessment Year [AY] 2015- 16 and in ITA No.1368/Bang/2024 in respect of AY 2016-17. 3. The Revenue had preferred the said appeals before the learned Tribunal

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

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

ITA/680/2015HC Karnataka15 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 10ASection 143(3)Section 260Section 260ASection 80H

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 2004-05. The appeal was admitted by a bench of this Court vide order dated 24.08.2016 on the following substantial question of law: "Whether the Tribunal is correct

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TEXPORT OVERSEAS PVT LTD

ITA/392/2018HC Karnataka12 Dec 2019

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

Section 143(3)Section 144C(13)Section 14ASection 260ASection 8(2)(iii)Section 92BSection 92CSection 98B

260A OF INCOME TAX ACT, 1961 PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON’BLE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED:12.09.2018 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH, BANGALORE, IN APPEAL PROCEEDINGS NO.IT(TP)A NO.2213/BANG/2018 (ANNEXURE

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

260A of the Income Tax Act, 1961 (‘Act’ - 5 - for short) challenging the order dated 19.08.2016 passed by the Income Tax Appellate Tribunal, Bangalore Bench “C”, Bengaluru (‘Tribunal’ for short) in ITA No.1428/Bang/2014 relating to the Assessment Year 2006-07. 5. The respondent – assessee (ITA No.653/2016) claims to be a company involved in the business of transport and had filed

THE PR COMMISSIONER OF INCOME TAX-1 vs. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD

Appeal of the revenue is hereby dismissed

ITA/145/2025HC Karnataka20 Aug 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 260Section 260ASection 92C

Section 260A of the Income Tax Act, 1961 [the Act], impugning an order - 3 - HC-KAR NC: 2025:KHC:32339-DB ITA No. 145 of 2025 dated 09.12.2024 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT]. 3. The impugned order is a common order passed in IT (TP) A No. 593 / Bang / 2020 in respect of assessment

THE DIRECTOR OF INCOME-TAX vs. M/S. INTEL CAPITAL (CAYMAN) CORPORATION

In the result, the appeal fails and is hereby

ITA/385/2013HC Karnataka06 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 115ASection 143(3)Section 144CSection 260Section 260ASection 47

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 2008-09. The appeal was admitted by a bench of this Court vide order dated 27.11.2015 on the following substantial question of law: Whether on the facts

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

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 to consider the following substantial question of law; - 3 - “Whether on the facts

M/S PADMINI PRODUCTS (P) LTD., vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the aforesaid

ITA/154/2014HC Karnataka05 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 147Section 148Section 260Section 260ASection 32(1)Section 43(1)

260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the assessee. The subject matter of the appeal pertains to the Assessment years 2005-06 to 2008-09. The appeal was admitted by a bench of this Court vide order dated 26.09.2014 on the following substantial question of law: (i) Whether

THE PR COMMISSIONER OF INCOME TAX CIT(A) vs. M/S GENISYS INFORMATION

ITA/698/2017HC Karnataka05 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260A

SECTION 260A OF THE INCOME TAX ACT, 1961, PRAYING TO I) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE II) ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE INCOME-TAX APPELLATE TRIBUNAL, BENGALURU IN IT(TP)A NO.59/BANG/2014 DATED 22.02.2017 ANNEXURE-D CONFIRMING THE ORDER OF THE DRP AND CONFIRM THE ORDER PASSED BY THE ASST. COMMISSIONER

COMMISSIONER OF INCOME TAX-III vs. M/S YODLEE INFOTECH PVT LTD

The appeal is disposed of

ITA/51/2014HC Karnataka28 Sept 2020

Bench: ALOK ARADHE,M.I.ARUN

Section 10BSection 115JSection 143(1)Section 260Section 260ASection 92C

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 2008-09. The appeal was admitted by a bench of this Court vide order dated 15.07.2014 on the following substantial questions of law: (i) Whether

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

ITA/419/2016HC Karnataka08 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 115JSection 143Section 144CSection 260Section 260ASection 37Section 92C

260A of the Income Tax Act, 1961 [‘Act’ for short] assailing the order of the Income Tax Appellate Tribunal, Bangalore Bench “B” (‘Tribunal’ for short), dated 29.04.2016 passed in ITA No.1282/Bang/2011 relating to the assessment year 2007-08. 2. The matter was admitted to consider the following substantial questions of law: “1. Whether, on the facts and in the circumstances

PR COMMISSIONER OF vs. M/S ZYME SOLUTIONS P LTD

ITA/548/2016HC Karnataka26 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260Section 260A

SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON’BLE Court AS DEEMED FIT, AND SET ASIDE THE APPELLATE ORDER DATED 22/01/2016 PASSED BY THE ITAT, ‘B’ BENCH, BENGALURU, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEE’S CASE, IN Date

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

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 2008-09. The appeal was admitted by a bench of this Court vide order dated 19.03.2020 on the following substantial questions of law: "(i) Whether on the facts

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

ITA/464/2017HC Karnataka09 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10ASection 260Section 260ASection 32

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 2008-09. The appeal was admitted by a bench of this Court vide order dated 22.11.2017 on the following substantial questions of law: (1) Whether on the facts