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3,426 results for “transfer pricing”+ Section 13(1)(c)clear

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Key Topics

Section 143(3)79Addition to Income54Disallowance37Section 14A30Transfer Pricing25Section 115J21Deduction21Section 153A16Section 92C16

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1053/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jul 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

Showing 1–20 of 3,426 · Page 1 of 172

...
Section 271(1)(c)15
Section 25014
Section 10(38)13

In the result all In the result all appeals of the assesses from AY 2014

ITA 1051/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jul 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1052/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1054/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Jul 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

C shows that assessee has sold 20 products to that entity amounting to ₹ 1 66 6 lakhs. The assessee benchmarked these transactions determining FO be sale price per unit to other parties, made adjustment with respect to cost for additional credit period to the associated enterprise and Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 reduced it by ECGC

DCIT 8(1), MUMBAI vs. CASTROL INDIA LTD, MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 7922/MUM/2010[2003-04]Status: DisposedITAT Mumbai29 Jul 2016AY 2003-04

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Peejush Sonkar, Sr. Counsel a/wFor Respondent: Shri N.K. Chand
Section 271(1)(c)

section 271(1)(c) of the Act. 10. In the result, assessee’s appeal is allowed. ITA no.7922/Mum./2010 – A.Y. 2003–04 11. In this appeal, the Department has raised the following grounds:– “1. The Ld.CIT(A) has erred in deleting the penalty levied in relation to the transfer pricing adjustments made of Rs.3,46,12,406/- u/s.92CA

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

section 144C(13) of the Income-tax Act, 1961 ('Act'), the Appellant respectfully submits that the learned A0 erred in passing the order on the following grounds: 1. In making an upward transfer pricing adjustment of Rs. 946,786,679 in determining the arms length pricing (ALP) of the international transactions pertaining to (a) investment advisory services in respect

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

Section 143(3)Section 144C(5)

c. Payment for interest on ECB loan 51,74,209 d. Payment for software charges 2,21,62,308 Total 9,89,08,525 4. The Ld. AO has passed draft assessment order u/s 143(3) r.w.s. 144C(1) of the I.T. Act, 1961 on 30-11-2017 and made TP adjustment as suggested by the 6 ITA 6081/Mum/2018

JSW ENERGY LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING) 2(3)(1), MUMBAI

In the result, the appeal is allowed

ITA 1223/MUM/2019[2014-15]Status: DisposedITAT Mumbai12 Aug 2022AY 2014-15

Bench: Us Is A Public Company Engaged In The Business Of Generation Of Power & Operation & Maintenance Of The Power Plants, As Also Other Allied Activities. During The Course Of Its Assessment Proceedings, The Assessing Officer Made A Reference Under Section 92Ca(1), For Determination Of The Arm‟S Length Price Of The International Transactions & Specified Domestic Transaction Entered Into By The Assessee With Its Associated Enterprises (Aes), To The Deputy Commissioner Of Income Tax, Assessment Year 2014-15 Page 2 Of 17

Section 271GSection 92CSection 92D

C. The Transfer Pricing study report (for specified domestic transaction) was submitted to Transfer Pricing Officer on 07.07.2017 (para 14 of written submission). D. There was no application of mind on part of Transfer Pricing Officer (para 20 of written submission). E. It is not recorded in the assessment order that penalty proceedings under section 271G is separately initiated (Para

DCIT - (LTU) - 1 , MUMBAI vs. RELIANCE INDUSTRIES LTD., MUMBAI

In the result, the appeals filed by the Revenue and Cross Objections filed by the assessee are dismissed

ITA 6267/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Mar 2020AY 2009-10

Bench: Shri G. Manjunatha & Shri Ravish Sood

For Appellant: Shri Jitendra Yadav &For Respondent: Shri H.N. Singh (CIT-DR)
Section 271(1)(c)Section 92C

section 271(1)(c) cannot be levied. Reliance is placed in the following decisions - • CIT vs SSA's Emerald Meadows (SC). ITA No 380 of 2015 • CIT vs Samson Perinchery (SLP)(392 ITR 4) (BOM) • CIT vs Manjunatha Cotton & Ginning Factory (359 ITR 565) (Kar) p) The final penalty is imposed by invoking Explanation 1 for furnishing inaccurate particulars

DCIT 10(1), MUMBAI vs. SYMANTIC SOFTWARE SOLUTIONS P.LTD, MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 4356/MUM/2014[2006-07]Status: DisposedITAT Mumbai31 Mar 2016AY 2006-07

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri A.V. SondeFor Respondent: Shri N.K. Chand a/w
Section 271(1)(c)Section 40

transfer pricing adjustment which is as under:– “Whether in the facts and circumstances of the case, the Appellate Tribunal’s confirmation of the determination of the arm's length price margin at 17.50 per cent for marketing support and consultancy services provided by the Appellants to its associated enterprises in the assessment year 2006–07 is correct and proper