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970 results for “transfer pricing”+ Section 132(1)clear

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Key Topics

Section 14A92Section 143(3)86Addition to Income80Disallowance57Section 69C56Section 153A42Section 13231Section 153C25Section 6824

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

Showing 1–20 of 970 · Page 1 of 49

...
Deduction20
Section 10(38)17
Survey u/s 133A16

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

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

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

ITA 4512/MUM/2014[2005-06]Status: DisposedITAT Mumbai04 Apr 2017AY 2005-06

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

132 of the Act, notice under 28 M/s Salasar Developers ITA No.4511 TO 4513/Mum/2014 Section 153 A(1) will have to be mandatorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

ITA 4511/MUM/2014[2004-05]Status: DisposedITAT Mumbai04 Apr 2017AY 2004-05

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

132 of the Act, notice under 28 M/s Salasar Developers ITA No.4511 TO 4513/Mum/2014 Section 153 A(1) will have to be mandatorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date

ASST CIT CIR 2, THANE vs. SALASAR DEVELOPERS, THANE

The appeals of the Revenue are dismissed

ITA 4513/MUM/2014[2006-07]Status: DisposedITAT Mumbai04 Apr 2017AY 2006-07

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 132Section 132(3)Section 133ASection 143(3)Section 153A

132 of the Act, notice under 28 M/s Salasar Developers ITA No.4511 TO 4513/Mum/2014 Section 153 A(1) will have to be mandatorily issued to the person searched requiring him to file returns for six AYs immediately preceding the previous year relevant to the AY in which the search takes place. ii. Assessments and reassessments pending on the date

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

132/-. The Transfer Pricing Officer, on a reference under section 92CA(1) of the Act has passed an order under

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

pricing provision is applicable. 54 Viacom 18 Media Pvt. Ltd. 119. Considered the rival submissions and perused the material on record. We find that the issue arising out of the aforesaid ground of appeal has been decided by the Tribunal in assessee‟s own case in ACIT v/s M/s. Viacom 18 Media Pvt. Ltd., ITA no. 8406/Mum./2010, order dated

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

1,06,57,180/-. As assessee has entered into seven different types of international transactions, the learned Assessing Officer referred to determine its Arm's Length Price to the learned Transfer Pricing Officer. The learned Transfer Pricing Officer found that assessee has entered into different international transactions of receipt and payment of commission/ fees for non media services, client

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

1,06,57,180/-. As assessee has entered into seven different types of international transactions, the learned Assessing Officer referred to determine its Arm's Length Price to the learned Transfer Pricing Officer. The learned Transfer Pricing Officer found that assessee has entered into different international transactions of receipt and payment of commission/ fees for non media services, client

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

1,06,57,180/-. As assessee has entered into seven different types of international transactions, the learned Assessing Officer referred to determine its Arm's Length Price to the learned Transfer Pricing Officer. The learned Transfer Pricing Officer found that assessee has entered into different international transactions of receipt and payment of commission/ fees for non media services, client

NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

ITA 3420/MUM/2017[2007-08]Status: DisposedITAT Mumbai08 Jan 2018AY 2007-08

Bench: Shri Joginder Singh, Assessment Year: 2007-08

Section 133(6)Section 143(1)Section 143(2)Section 148Section 68Section 69C

transferred to some other account. (iv) It means that Bhanwarlal Jain Group companies are providing only accommodation entries and no genuine transactions. In the light of the above facts, the Ld. Assessing Officer treated the amount of Rs.25 lakhs taken as loans/advances as unexplained cash credit u/s 68 of the Act. 2.2. On appeal before the Ld. Commissioner of Income

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

ITA 3644/MUM/2016[2008-09]Status: DisposedITAT Mumbai03 Feb 2020AY 2008-09

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

For Appellant: Shri P.J. Pardiwalla &For Respondent: Shri Anadi Varma, CIT-DR&
Section 143(3)Section 147

price whichever is lower, and it is now generally accepted as an established rule of commercial practice and accountancy. As profits for income-tax purposes are to be computed in conformity with the ordinary principles of commercial accounting, unless of course, such principles have been superseded or modified by legislative enactments unrealised profits in the shape of appreciated value