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9 results for “transfer pricing”+ Section 9(1)(v)clear

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Delhi3,880Mumbai3,514Bangalore1,625Chennai886Kolkata675Ahmedabad643Hyderabad507Karnataka448Jaipur393Pune359Chandigarh252Indore227Cochin198Surat143Visakhapatnam115Rajkot108SC99Nagpur73Telangana73Cuttack65Calcutta65Lucknow63Raipur47Amritsar34Guwahati31Jodhpur29Agra29Dehradun28A.K. SIKRI ROHINTON FALI NARIMAN15Ranchi13Varanasi12Allahabad11Rajasthan10Kerala9Panaji7Patna6Jabalpur6Orissa6Punjab & Haryana3DIPAK MISRA V. GOPALA GOWDA1MADAN B. LOKUR S.A. BOBDE1S.B. SINHA MARKANDEY KATJU1A.K. SIKRI N.V. RAMANA1D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1

Key Topics

Section 143(3)5Section 36(1)(iii)4Section 92C3Disallowance3Section 144C2Section 2(14)2Transfer Pricing2Addition to Income2Deduction

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

9 (2013) 33 taxmann.com 575 (Cochin-Trib.) ITA No.44/2017 -23- clarify that both the above judgments allow deduction under section 37 of the 1961 Act and not under section 36(1)(iii) of the 1961 Act. In this case, the Tribunal has allowed the claim under section 37 and not only section 36(1)(iii), hence there is no infirmity

2

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. 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

9 I.T.A.No.68/2020 Sri.Jose Thomas 2011-12 I.T.A.No.238/2019 10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering

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

9 I.T.A.No.68/2020 Sri.Jose Thomas 2011-12 I.T.A.No.238/2019 10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering

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

9 I.T.A.No.68/2020 Sri.Jose Thomas 2011-12 I.T.A.No.238/2019 10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering

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

9 I.T.A.No.68/2020 Sri.Jose Thomas 2011-12 I.T.A.No.238/2019 10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering

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

9 I.T.A.No.68/2020 Sri.Jose Thomas 2011-12 I.T.A.No.238/2019 10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering

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

9. Senior Advocate Mr Joseph Markos, to enable the Court to appreciate the intricacy involved in the substantial question raised by the assessee, has prefaced his submission by inviting our attention to paragraph 31 of the Tribunal’s order, which reads thus: “31. We have heard both the parties and perused the record. In our opinion, gain earned from cancellation

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

1) Whether the land was classified in the revenue records as agricultural and whether it was subject to the payment of land revenue? 8 139 ITR 628 I.T.A. No.179/2014 -18- (2) Whether the land was actually or ordinarily used for agricultural purposes at or about the relevant time? (3) Whether such user of the land was for a long period