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11 results for “transfer pricing”+ Addition to Incomeclear

Sorted by relevance

Delhi5,365Mumbai5,196Bangalore2,006Chennai1,094Kolkata1,007Ahmedabad783Hyderabad760Pune654Jaipur468Karnataka448Surat299Chandigarh280Indore275Cochin227Visakhapatnam132Rajkot131Cuttack83Nagpur81Lucknow79Telangana75Calcutta68SC61Raipur59Amritsar57Agra35Guwahati35Dehradun34Jodhpur34Jabalpur17Ranchi16Varanasi12Allahabad12Kerala11Panaji11Patna10Rajasthan10Orissa6A.K. SIKRI ROHINTON FALI NARIMAN4Punjab & Haryana3Andhra Pradesh2D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1

Key Topics

Section 143(3)10Section 144C6Addition to Income5Section 92C4Section 36(1)(iii)4Section 353Section 2633Transfer Pricing3Deduction3Section 143(2)

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S. APOLLO TYRES LTD

Appeal is allowed in part as indicated

ITA/44/2017HC Kerala22 Sept 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

For Appellant: M/S. APOLLO TYRES LTDFor Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX
Section 143(3)Section 144CSection 144C(5)Section 35Section 43ASection 92C

Transfer Pricing Officer-1, Kochi, made the order under Section 92CA(3) ITA No.44/2017 -3- of the Act. The Assessing Officer through Annexure-B draft assessment order dated 28.03.2014 proposed to finalize the income tax return of the assessee assessed total income as Rs.481,78,02,530/-. The assessee raised objections to the draft assessment order dated 28.03.2014. The issues

2
Section 144C(5)2
Disallowance2

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. JOSE THOMAS

ITA/46/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. SMT.GRACY BABU,

ITA/54/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. REENA JOSE

ITA/47/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. GRACY BABU,

ITA/48/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. JOSE THOMAS,

ITA/56/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

M/S. JOYALUKKAS INDIA LTD, vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,

In the result, the appeal fails and the substantial questions

ITA/10/2019HC Kerala21 Dec 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: M/S.JOYALUKKAS INDIA LTDFor Respondent: THE ASSISTANT COMMISSIONER OF INCOME TAX
Section 143Section 143(1)Section 143(3)Section 144CSection 36(1)(iii)Section 92C

Income Tax Act. 3. The Dispute Resolution Panel by Annexure-A communication concurred with the findings of the Transfer I.T.A. No.10/2019 3 Pricing Officer and resulted in a draft order dated 25.03.2014 under Section 143(3) read with 144C(1) of the Act. Though objections to the draft order were filed before the dispute resolution panel, the panel vide order

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.APOLLO TYRES LIMITED

ITA/36/2017HC Kerala04 Aug 2021

Bench: This Court. The Issues Canvassed In The Appeal Relate To Assessment Year 2010-11. Prefaced In The Beginning, The Issues Raised By The Revenue Arise Under Section 144C Read With Section 143(3) Vis-A-Vis Section 263 Of The Income Tax Act, 1961 (For Short 'The Act').

Section 143(3)Section 144CSection 263Section 35Section 40

additions etc made by the Assessing Officer. In the case on hand, the objections were filed by the assessee. This resulted in the draft assessment order in Annexure-B, being forwarded to DRP for decision and issuance of directions to the Assessing Officer. The DRP, in Annexure-C dated 26.12.2014, issued directives which resulted in Annexure- D order dated

THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOCHI -I vs. M/S.APOLLO TYRES LTD

ITA/43/2017HC Kerala31 Aug 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

For Appellant: THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOCHI -IFor Respondent: M/S.APOLLO TYRES LTD
Section 143(3)Section 144C(5)Section 32(1)(iia)Section 35Section 80Section 92C

additional depreciation brought forward from immediately preceding assessment year has to be allowed in the subsequent assessment year and is nto the above finding against law and perverse? 2. Whether on the facts and in circumstances of the case is the Hon'ble ITAT is right in law in allowing the assessee's claim of weighted deduction under Section

SHRI JOSEPH THANNIKOTTU KORAH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX,

ITA/310/2019HC Kerala25 Mar 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

Section 143(2)

transferred 76.73 ares of land to one Sri Sajiv ITA NO. 310 OF 2019 -3- Mathai for a total consideration of Rs.3,35,700/-. The assessee produced the sale deed dated 20.1.2011. The case of the assessee is that though the document value is only Rs.3,35,700/-, the actual consideration was for Rs.31,00,000/- including an advance

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. USHA MURUGAN

ITA/18/2017HC Kerala23 Jun 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR. JUSTICE BECHU KURIAN THOMAS

Section 143(2)Section 260A

addition of the said amount is impermissible. The Assessing Officer, from the details and materials available on record, held that the relationship between the assessee and the end buyers of lottery tickets is one of Principal and Agent; the incentive/commission has been paid after deducting tax at source and the total payment is liable to be disallowed under Section