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12 results for “transfer pricing”+ Section 6clear

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Key Topics

Section 143(3)8Section 144C6Section 36(1)(iii)4Addition to Income4Section 92C3Section 143(2)3Section 2633Disallowance3Deduction3

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

Section 402
Section 260A2
Transfer Pricing2

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

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 dated 29.12.2014 upheld some of the additions proposed in the draft assessment order and thereafter the respondent passed

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

6. We have heard the learned counsel appearing for the parties and also perused the record. At the outset, we make it clear that in the case on hand we are not examining the scope and applicability of Section 263 vis-a-vis a final assessment order made pursuant to directions of DRP, under Section 144C read with Section

M/S. APPOLLO TYRES LTD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

ITA/249/2015HC Kerala26 Aug 2021

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

Section 40

6. Mr Joseph Markos appearing for the assessee tried to convince this Court to take a different view by the very same argument put forward by the assessee before the Tribunal and the Assessing Officer. We have two difficulties in appreciating the argument of the assessee to accept the provision made towards commission payable to the agents through whom sales

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

6. The learned Counsel appearing for the parties have, in great detail, invited our attention to all the three orders of the authorities filed as Annexures A to C. The arguments now made in support of the respective cases by the learned counsel are I.T.A. Nos. 18, 13 & 29/2017 -10- similar to the arguments made before the CIT(Appeals

THE COMMISSIONER OF INCOME TAX-1, KOCHI vs. M/S.COCHIN MALABAR ESTATES & INDUSTRIES LTD.

ITA/179/2014HC Kerala28 Oct 2021

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

Section 143(2)Section 2(14)Section 2(14)(iii)Section 260A

6) Whether the land, on the relevant date, had ceased to be put to agricultural use? If so, whether it was put to an alternative use? Whether such cesser and/or alternative user was of a permanent or temporary nature? (7) Whether the land, though entered in revenue records, had never been actually used for agriculture, that is, it had never

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

6. In I.T.A.No.47/2020, the following substantial questions of law have been raised: (i) Whether the trustees of a public charitable trust have a right to trusteeship and if they need to be compensated for relinquishing such right ? (ii) Whether the trusteees are entitled to such benefits from the trust other than remuneration for services rendered by them ? (iii) Whether

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

6. In I.T.A.No.47/2020, the following substantial questions of law have been raised: (i) Whether the trustees of a public charitable trust have a right to trusteeship and if they need to be compensated for relinquishing such right ? (ii) Whether the trusteees are entitled to such benefits from the trust other than remuneration for services rendered by them ? (iii) Whether

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

6. In I.T.A.No.47/2020, the following substantial questions of law have been raised: (i) Whether the trustees of a public charitable trust have a right to trusteeship and if they need to be compensated for relinquishing such right ? (ii) Whether the trusteees are entitled to such benefits from the trust other than remuneration for services rendered by them ? (iii) Whether

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

6. In I.T.A.No.47/2020, the following substantial questions of law have been raised: (i) Whether the trustees of a public charitable trust have a right to trusteeship and if they need to be compensated for relinquishing such right ? (ii) Whether the trusteees are entitled to such benefits from the trust other than remuneration for services rendered by them ? (iii) Whether

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

6. In I.T.A.No.47/2020, the following substantial questions of law have been raised: (i) Whether the trustees of a public charitable trust have a right to trusteeship and if they need to be compensated for relinquishing such right ? (ii) Whether the trusteees are entitled to such benefits from the trust other than remuneration for services rendered by them ? (iii) Whether

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