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323 results for “transfer pricing”+ Permanent Establishmentclear

Sorted by relevance

Delhi413Mumbai323Chennai59Bangalore47Jaipur24Visakhapatnam19Raipur17Kolkata14Indore13Pune11Chandigarh11Ahmedabad10Cuttack7Cochin6Rajkot5Hyderabad4Lucknow4Jabalpur2Nagpur1Dehradun1Amritsar1

Key Topics

Section 20180Section 14A51Addition to Income50Section 143(3)45Double Taxation/DTAA43Permanent Establishment40Disallowance35Deduction27Transfer Pricing21

TAJ TV LTD.,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-4(1)(2), MUMBAI

ITA 821/MUM/2021[2017-18]Status: DisposedITAT Mumbai31 Mar 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Taj Tv Limited Dcit (International C/O. Suresh Surana & Taxation)-4(1)(2) Associates Llp Air India Building, 8Th Floor, Bakhtawar, Vs. Nariman Point, Nariman Point, Mumbai-400 Mumbai-400 021 020 (Appellant) (Respondent) Pan No. Aabct6542J Reference Of Orders / Directions In Appeal Sr Orders & Directions Passed By Date No 1 Draft Assessment Order U/S The Deputy 27/12/2019 144C Of The Act Commissioner Of Income Tax , International Taxation, Circle 4 (1) (2), Mumbai 2 Direction U/S 144C (5) Of The Cit (Drp-2) , 22/03/2021 Act Mumbai - 2 3 Assessment Order U/S 143 93) The Deputy 12/04/2021 R.W.S 144C (13) Of The Act Commissioner Of Income Tax , International Taxation, Circle 4 (1) (2), Mumbai

For Appellant: Shri P.J. Pardiwala Sr AdvFor Respondent: Shri G.C. Srivastava, Adv
Section 143Section 144C

permanent establishment in India. xxvi. It was further vehemently stated that revenue has not to demonstrate any further. He once again referred to the transfer pricing

Showing 1–20 of 323 · Page 1 of 17

...
Business Income18
Section 1413
TDS13

DDIT (IT) 2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4550/MUM/2013[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 5228/MUM/2004[2000-2001]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-2001

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. ADIT (IT) RG 2(1), MUMBAI

Appeals are disposed off

ITA 3617/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. DCIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 1287/MUM/2009[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. ADIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 5182/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

DDIT (INTERNATIONAL I. T) 2(1), MUMBAI vs. M/S. REUTERS ON LINE S.A, MUMBAI

Appeals are disposed off

ITA 5379/MUM/2005[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

ADIT (IT) RG 2, MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 5155/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1978/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD,MUMBAI vs. THE DDIT (IT)-2(1), MUMBAI

Appeals are disposed off

ITA 1708/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1979/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. THE DDIT (IT)-2(1), MUMBAI

Appeals are disposed off

ITA 1709/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. DDIT (I.T) - 2(1), MUMBAI

Appeals are disposed off

ITA 3422/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. DDIT (I.TAXATION) RANGE 2, MUMBAI

Appeals are disposed off

ITA 5092/MUM/2004[2000-01]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-01

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

ADIT (IT)-2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4575/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

REFINITIV LTD.,MUMBAI vs. THE DY DIT (I.T) 2(1), MUMBAI

Appeals are disposed off

ITA 8348/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

THE DDIT (I.T) 2(1) vs. M/S. REUTERS LTD.,

Appeals are disposed off

ITA 8463/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

THE DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 8464/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

ADIT (IT)-2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 3366/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

permanent establishment is merely academic and does not call for any adjudication. He therefore submitted that even in those cases, the dependent agent is adequately remunerated and there is no indication or finding that the functions performed by the dependent agent are more than what is accepted by the transfer pricing

UPS ASIA GROUP PTE LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX(INTRNATIONAL TAXATION)-4(3)(1), MUMBAI

In the result, the appeals of the assesse are dismissed

ITA 2243/MUM/2022[2018-19]Status: DisposedITAT Mumbai24 Jan 2023AY 2018-19

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: Nitesh JoshiFor Respondent: Soumendu Kumar Dash
Section 143(3)Section 9(1)Section 9(1)(i)

permanent establishment, would not be taxable in India. The Tribunal in fact in para 10 has recorded a finding that Article 7(2) provides that the arm's length price is the criterion for computation of these hypothetical profits. In our opinion the entire rational or reasoning given by the Tribunal has to be set aside. In matters