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318 results for “transfer pricing”+ Section 90(2)clear

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Key Topics

Addition to Income53Section 26019Section 1487Section 10A6Section 10B4Deduction4Section 260A3Section 43Section 1473

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

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

Showing 1–20 of 318 · Page 1 of 16

...
Section 65(1)3
Comparables/TP3

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

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)

90,672/-, which was for reasons other than the one recorded in the notice. During the relevant period, the assessee had sold a plot of land measuring 12,430 sq. ft. for a consideration of Rs.74,58,000/-. The property devolved upon the assessee in a family partition in the year 1972. Assessee treated it as a case of sale

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)

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

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)

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

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)

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

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

90,62,637 Income from business of the undertaking after voluntary TP adjustment 80,51,42,179 7. The AO had denied the exemption under Section 10AA on the TP pricing adjustment made pursuant to the APA. The AO reasoned that the assessee had declared the TP adjustments in anticipation of such TP adjustments by the TPA and to avoid

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

90. M Sebastian, s/o K C Devasia, aged about 54 years, working as Pharma Assistant Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road, Bangalore-560049 91. U.S. Bati, s/o Sonnappa Bati, aged about 55 years, working as Pharma Assistant Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, 27 Off Old Madras Road, Bangalore-560049 92. Cecilia A D Cruz, D/o John Martin

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA CO-OPERATIVE MILK PRODUCERS

Appeal is dismissed with costs

ITA/70/2007HC Karnataka26 Sept 2012

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

2. 2009 (7) SCC 363 - Suraj Lamp and Industries Private Limited. -Vs- State of Haryana & Another 3. 2010 (8) SCC 383 - Meghamala and Ors.-Vs-G Narasimha Reddy and Ors. 4. 2011(9) SCC 1 - K.T.Plantation Private Limited & Anr. Vs. State of Karnataka”. 95. As discussed above, with reference to Section 54 of the Transfer of Property Act, the sale

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)

transferred from IDBI Bank to Akash Ranka’s account in Karur Vysya Bank as an interim measure to enable the firm to pay the outstanding bills for smooth functioning of the work. 35 28. Such an admission in the statement of objection would be sufficient enough to hold that there was misdeed committed by the first respondent detrimental

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

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

ITA/149/2025HC Karnataka02 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 144Section 260

2. The Revenue has filed the present appeal under Section 260-A of the Income Tax Act, 1961 [the Act] impugning an order dated 04.09.2024 passed by the learned Income Tax Appellate Tribunal [ITAT] in MP.No.63/Bang/2023 in IT(TP)A. - 3 - HC-KAR NC: 2025:KHC:34395-DB ITA No. 149 of 2025 No.2806/Bang/2017 in respect of the Assessment

SRI U M RAMESH RAO vs. UNION BANK OF INDIA

In the result, the writ appeals are disposed in

WA/538/2020HC Karnataka29 Jan 2021

Bench: B.V.NAGARATHNA,R. NATARAJ

Section 17Section 31Section 4

price is less than eight times the net annual income of the land. (2) Nothing in sub-section (1) shall apply to lands granted under Section 77. -: 80 :- 81. Sections 79-A, 79-B, and 80 not to apply in certain cases.- (1) Nothing in Section 79-A or Section 79-B or Section 80 shall apply

M/S SSJV PROJECTS PRIVATE LIMITED vs. M/S ALLAHABAD BANK

In the result, the writ appeals are disposed in

WA/545/2020HC Karnataka29 Jan 2021

Bench: B.V.NAGARATHNA,R. NATARAJ

Section 17Section 31Section 4

price is less than eight times the net annual income of the land. (2) Nothing in sub-section (1) shall apply to lands granted under Section 77. -: 80 :- 81. Sections 79-A, 79-B, and 80 not to apply in certain cases.- (1) Nothing in Section 79-A or Section 79-B or Section 80 shall apply

IRON ORE END USERS ASSOCIATION vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43951/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section

M/S PADMAVATHI FERROUS LTD vs. GOVERNMENT OF KARNATAKA

In the result, these petitions must succeed

WP/49694/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section

SATHVAHANA ISPAT LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43871/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section

M/S. BMM ISPAT LTD vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43969/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section

HINDUSTAN CALCINED METALS PRIVATE LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/46232/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section

GERDAU STEEL INDIA PRIVATE LIMITED vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

WP/44993/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

90 “7. In Guru Siddappa v State of Karnataka AIR 1981 Kar 216, the Division Bench of the Karnataka High Court had held that the Forest Development Tax (FDT) levied on the purchase price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section