Search: transfer pricing | BharatTax

Search ITAT High Courts Supreme Court AI Research History

Filters

Sort by

Assessment Year

Order Date From

Order Date To

Judge Name

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.

14 results for “transfer pricing”+ Section 928clear

Sorted by relevance

Mumbai98 Delhi73 Hyderabad15 Ahmedabad14 Kolkata14 Cuttack9 Chandigarh8 Chennai7 Jaipur7 Bangalore6 Visakhapatnam4 Pune2 Ranchi1 Cochin1

Key Topics

Section 115J17 Section 234B12 Addition to Income10 Section 50C8 Section 2507 Section 92C7 Section 143(3)5 Deduction5 Section 143(1)4

DCIT, CIR-4(1), KOLKATA, KOLKATA vs. M/S MCLEOD RUSSEL INDIA LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2279/KOL/2019[2014-15]Status: DisposedITAT Kolkata07 Jul 2023AY 2014-15

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumar

transfer pricing adjustment is possible. However in view of the amendment as set out above and insertion of the Explanation to Section 928

DCIT, KOLKATA vs. HIMADRI SPECIALITY CHEMICAL LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2223/KOL/2025[2012-13]Status: DisposedITAT Kolkata17 Feb 2026AY 2012-13

Section 115JSection 92C

Rectification u/s 1544

Transfer Pricing Officer computed the Arm's Length Price of SBLC issued by the SBI at the rate of 1.62% which comes to ₹9,92,126/-. While, the Id. CIT (A) reduced the Arm's Length Price to 0.5% by observing and holding as under:-\n\"4.6 Furthermore, the assessee emphasized that the guarantee transaction was not specifically designed

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 373/KOL/2021[2015-16]Status: DisposedITAT Kolkata17 Sept 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR

Section 250Section 43(6)Section 50CSection 50C(2)Section 928

928 of the Act. 1.2. disregarding the fact that the provision of corporate guarantee to the AEs was for the purpose of furtherance of business by the Appellant, and consequently the guarantee was in the nature of shareholder services and thus a guarantee fee is not warranted. 1.3. making an ad-hoc adjustment of 200 basis points on the outstanding

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 372/KOL/2021[2014-15]Status: DisposedITAT Kolkata17 Sept 2024AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR

Section 250Section 43(6)Section 50CSection 50C(2)Section 928

928 of the Act. 1.2. disregarding the fact that the provision of corporate guarantee to the AEs was for the purpose of furtherance of business by the Appellant, and consequently the guarantee was in the nature of shareholder services and thus a guarantee fee is not warranted. 1.3. making an ad-hoc adjustment of 200 basis points on the outstanding

TATA CONSUMER PRODUCTS LIMITED (SUCCESSOR OF TATA COFFEE LTD.),KOLKATA vs. A.C.I.T., CIRCLE - 4(1), KOLKATA

Appeal of the assessee is partly allowed

ITA 2636/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 144Section 144BSection 144C(5)Section 153Section 438Section 43BSection 80MSection 928Section 92B

Transfer Pricing Officer (Ld. TPO)/ Learned Dispute Resolution Panel ('Ld. DRP") grossly erred in making an adjustment of INR 2,00,21,945 to the income of the Appellant on account of corporate guarantee fee. 3.1 That on the facts and circumstances of the case and in law, the Ld. TPO/ Ld. DRP erred in not appreciating the fact that

DCIT, CENTRAL CIRCLE 2(2), KOLKATA, KOLKATA vs. M/S. ULTRATECH NATHDWARA CEMENT LTD. (KNOWN AS M/S. BINANI CEMENT LTD.), KOLKATA

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 470/KOL/2018[2013-14]Status: DisposedITAT Kolkata28 May 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

section 928, and accordingly an arm's length charge should be imputed in relation to the same. 3. That on facts and in the circumstances of the case, the Ld. CIT(A) has erred in categorizing the corporate guarantee as shareholder service not warranting any charge. 4. That on the facts and in the circumstances of the case

BINANI CEMENT LTD.,MUMBAI vs. D.C.I.T., CENTRAL CIRCLE-XXVIII, KOLKATA, KOLKATA

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 1726/KOL/2014[2008-2009]Status: DisposedITAT Kolkata28 May 2025AY 2008-2009

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

section 928, and accordingly an arm's length charge should be imputed in relation to the same. 3. That on facts and in the circumstances of the case, the Ld. CIT(A) has erred in categorizing the corporate guarantee as shareholder service not warranting any charge. 4. That on the facts and in the circumstances of the case

ACIT, CIR-14(1), KOLKATA, KOLKATA vs. M/S. ULTRATECH NATHDWARA CEMENT LTD.(KNOWN AS M/S BINANI CEMENT LTD.), KOLKATA

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 611/KOL/2015[2010-2011]Status: DisposedITAT Kolkata28 May 2025AY 2010-2011

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

section 928, and accordingly an arm's length charge should be imputed in relation to the same. 3. That on facts and in the circumstances of the case, the Ld. CIT(A) has erred in categorizing the corporate guarantee as shareholder service not warranting any charge. 4. That on the facts and in the circumstances of the case

M/S. ULTRATECH NATHDWARA CEMENT LTD.(FORMERLY KNOWN AS M/S. BINANI CEMENT LTD.,),KOLKATA vs. DCIT, CENTRAL CIRCLE - 2(2), KOLKATA, KOLKATA

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 152/KOL/2018[2013-14]Status: DisposedITAT Kolkata28 May 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

section 928, and accordingly an arm's length charge should be imputed in relation to the same. 3. That on facts and in the circumstances of the case, the Ld. CIT(A) has erred in categorizing the corporate guarantee as shareholder service not warranting any charge. 4. That on the facts and in the circumstances of the case

ANIL KUMAR PAIK,KOLKATA vs. ACIT, KOLKATA

In the result, appeal of the assessee is allowed partly for statistical purposes

ITA 468/KOL/2023[2016-17]Status: DisposedITAT Kolkata29 Nov 2023AY 2016-17

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 468/Kol/2023 Assessment Year: 2016-17 Anil Kumar Paik Acit, Circle-8(1), Kolkata C/O S.N. Ghosh & Associates, Advocates Vs 2, Garstin Place, 2Nd Floor Suite No. 203 Off Hare Street Kolkata - 700001 [Pan : Aflpp6567R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Somnath Ghosh, Advocate Revenue By : Shri P.P. Barman, Addl. Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 21/09/2023 घोषणा क" तारीख /Date Of Pronouncement: 29/11/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi (Hereinafter The “Ld. Cit(A)”) Dt. 15/03/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri P.P. Barman, Addl. CIT, Sr. D/R

Section 143(2)Section 145(3)Section 250Section 43CSection 44A

928+ Rs.48,07,000) - (Rs.2,61,06,063+ Rs.39,96,040)} in place of Rs.3,48,64,832/-. Hence the excess liability comes to Rs.92,56,909/-. But due to inadvertent mistyping such amount was written as Rs.48,69,666/- in the show-cause notice dtd. 06.12.2018. 2.5. The assessee submitted ledger account of inter-proprietorship bank transaction in respect

DCIT, CIRCLE-8(1), KOLKATA, KOLKATA vs. ITC LIMITED, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1222/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

928/-). According to the AO the assessee should have deducted tax at source u/s 195 of the Act which was not deducted and hence the disallowance u/s 40a(i) of the Act. 14. In the appellant proceedings, the Ld. CIT(A) also dismissed the appeal of the assessee on this issue by rejecting the contentions of the assessee that

ITC LIMITED,KOLKATA vs. ACIT, RANGE-8, KOLKATA, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1166/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

928/-). According to the AO the assessee should have deducted tax at source u/s 195 of the Act which was not deducted and hence the disallowance u/s 40a(i) of the Act. 14. In the appellant proceedings, the Ld. CIT(A) also dismissed the appeal of the assessee on this issue by rejecting the contentions of the assessee that

DCIT, CIRCLE-8(1), KOLKATA, KOLKATA vs. ITC LIMITED, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1223/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

928/-). According to the AO the assessee should have deducted tax at source u/s 195 of the Act which was not deducted and hence the disallowance u/s 40a(i) of the Act. 14. In the appellant proceedings, the Ld. CIT(A) also dismissed the appeal of the assessee on this issue by rejecting the contentions of the assessee that

ITC LIMITED,KOLKATA vs. ACIT, RANGE-8, KOLKATA, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1068/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

928/-). According to the AO the assessee should have deducted tax at source u/s 195 of the Act which was not deducted and hence the disallowance u/s 40a(i) of the Act. 14. In the appellant proceedings, the Ld. CIT(A) also dismissed the appeal of the assessee on this issue by rejecting the contentions of the assessee that