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.

370 results for “transfer pricing”+ Section 36(1)clear

Sorted by relevance

Delhi2,742Mumbai2,636Bangalore1,085Chennai554Ahmedabad538Kolkata417Hyderabad388Karnataka370Jaipur312Pune307Chandigarh226Indore189Surat160Cochin138Visakhapatnam75SC60Lucknow59Calcutta57Rajkot51Telangana46Raipur43Nagpur35Cuttack34Guwahati30Agra29Amritsar28Jodhpur21Dehradun11Varanasi10Ranchi9Kerala9Jabalpur9Rajasthan8Allahabad7A.K. SIKRI ROHINTON FALI NARIMAN7Orissa6Panaji5DIPAK MISRA V. GOPALA GOWDA1Punjab & Haryana1MADAN B. LOKUR S.A. BOBDE1D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1

Key Topics

Addition to Income48Section 26030Section 1487Section 14A6Section 356Deduction5Section 2634Section 404Disallowance4

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

price has to be computed under section 92C of the Act, in the cases relating to an international transaction. The term international transaction has been defined in section 92B of the Act. Subsection (1) section 92B eads as under" for the purpose of this Act and section 92, 92C, 92D and 92E, International transaction" means a transaction between

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

Showing 1–20 of 370 · Page 1 of 19

...
Section 1093
Section 143(2)3
Transfer Pricing3
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

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

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

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

1 SCC 673, comparing the provisions of Section 260-A of the Act with Section 100 of the Civil Procedure Code, the Hon’ble Supreme Court held that in the absence of demonstrated perversity in the findings of the Tribunal, the Court cannot interfere and a finding of fact may give rise to a substantial question of law, only

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

1 SCC 673, comparing the provisions of Section 260-A of the Act with Section 100 of the Civil Procedure Code, the Hon’ble Supreme Court held that in the absence of demonstrated perversity in the findings of the Tribunal, the Court cannot interfere and a finding of fact may give rise to a substantial question of law, only

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

THE COMMISSIONER OF INCOME TAX vs. ING VYSYA BANK LTD

In the result, this appeal is allowed in part,

ITA/2886/2005HC Karnataka06 Jun 2012

Bench: B.MANOHAR,D.V.SHYLENDRA KUMAR

Section 143Section 260Section 36(1)(vii)Section 37(2)Section 80M

36(1)(vii). Therefore, on this aspect, the Revenue is in appeal before us raising the 3rd question for examination. 11. Yet another claim which became contentious before the Assessing Officer was relating to the amount that can be claimed as a part of its business expenditure which was in the nature of expenditure incurred or spent in respect

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

price in buying or selling. [Wharton's Law Lexicon, 1976 Reprint Ed.]. Expression “abatement” has been separately spelt out, in the same dictionary. “Abatement of criminal proceedings” has been termed to mean their termination 26 without a decision on the merits and without the assent of the prosecutor. If this is the legal position or meaning of abatement

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

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

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

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

transfer pricing [TP] adjustments of ₹14,82,00,000/-, which was reworked at ₹21,36,91,000/- on - 6 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 account of APA. Similarly, the Assessee had along with his return, made TP adjustments of ₹48,36

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

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/22348/2015HC Karnataka15 Dec 2015

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8)

36 stipulated in the said provision, the mandate is that the secured asset should not be sold or transferred by the secured creditor. It is further reinforced to the effect that no further step should also be taken by the secured creditor for transfer or sale of the secured creditor asset. The contingency stipulated in the event of the tender

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/29362/2015HC Karnataka15 Dec 2015

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8)

36 stipulated in the said provision, the mandate is that the secured asset should not be sold or transferred by the secured creditor. It is further reinforced to the effect that no further step should also be taken by the secured creditor for transfer or sale of the secured creditor asset. The contingency stipulated in the event of the tender

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

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

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

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