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2,220 results for “transfer pricing”+ Section 17(1)(iv)clear

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Delhi2,583Mumbai2,220Bangalore1,124Ahmedabad450Karnataka398Kolkata374Chennai364Hyderabad336Jaipur289Pune234Chandigarh211Surat201Indore185Cochin136Rajkot80Visakhapatnam64Calcutta64SC63Telangana54Lucknow46Nagpur45Raipur44Agra32Cuttack30Guwahati22Jodhpur20Amritsar16Dehradun16Ranchi11A.K. SIKRI ROHINTON FALI NARIMAN9Varanasi9Rajasthan8Panaji7Patna5Orissa5Kerala5Allahabad3Punjab & Haryana2Andhra Pradesh1A.K. SIKRI N.V. RAMANA1T.S. THAKUR ROHINTON FALI NARIMAN1

Key Topics

Section 143(3)53Addition to Income52Section 115J41Disallowance39Section 14A35Transfer Pricing32Section 145A19Deduction19Section 92C18

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

Showing 1–20 of 2,220 · Page 1 of 111

...
Comparables/TP16
Section 144C(5)15
Section 153A12

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

17,67,638/- for the reason that assessee was not free to price its products at Arm’s Length Price. iii. With respect to the interest on interest free advances given to the subsidiary companies, he upheld the action of the learned Transfer Pricing Officer but determines the rate of interest at 8.25% and direct the Transfer Pricing Officer

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

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

17. Brief facts are, in the course of proceedings before him, the Transfer Pricing Officer noticed that the assessee has paid an amount of ` 12,96,43,330, for availing Software Services, out of which, the assessee has capitalized an amount of ` 5,34,68,651, and claimed the balance amount of ` 7,61,74,677, as revenue expenditure. After

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

1), Mumbai Assessee by : Shri P.J. Pardiwallaa/w Shri Nishant Thakkar Revenue by : Shri Saurabh Deshpande Date of Hearing – 25.04.2018 Date of Order – 20.07.2018 O R D E R PER SAKTIJITDEY, J.M. The aforesaid appeal by the assessee is directed against assessment order dated 29th October 2010, passed under section 143(3) r/w 144C of the Income

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

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; Assessment year 2014-15 Page 11 of 17 (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length

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)

17. Learned Departmental Representative referring to the observations of the Transfer Pricing Officer / DRP submitted assessee is required to demonstrate that earlier year data has an impact on the profits of the current financial year of the assessee as well as the comparable companies which have not been done by the assessee. He further submitted, assessee’s contention cannot

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)

iv) Profit Split Method; v) Transactional Net Margin Method; and vi) Such other methods, as may be prescribed by the Board. 12. Rule 10B of Income Tax Rules, 1962 (for short “the Rules”), provides the mechanism for determination of arm's length price under the aforesaid methods prescribed under section 92C of the Act. If the 24 ITA 6081/Mum/2018 Assessing

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

iv) and 36(1)(v) of the Act specifically deal with contribution to a recognized provident fund or an approved superannuation fund or an approved gratuity fund. The said sections do not deal with providing for a liability vis-à-vis pension or any other retirement benefits. Thus, the aforesaid provision for pension made on the basis of an actuarial

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

1), Mumbai v/s Accenture Services Pvt. Ltd. C/o SRBC Associates & LLP 14th Floor, The Ruby ……………. Respondent 29, Senapati Bapat Marg Dadar (W), Mumbai 400 028 PAN – AACCA8997K Assessee by : Shri P.J. Pardiwalaa/w Shri Hiten Chande, Shri Nishant Thakkar, Shri Mukesh Butani & Shri Shreyash Shah Revenue by : Shri Anand Mohan Date of Hearing – 22.04.2019 Date of Order

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)

iv) TNM method working for the last three years submitted to the Transfer Pricing Officer vide letter dated 07/10/2011, placed at pages 110 of the Paper Book. The Ld. Representative for the assessee pointed out that the above information was submitted at the instance of the Transfer Pricing Officer himself, which clearly demonstrates that the TNM method workings have been

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

1 (a) to section 263 of the Act is also amended with effect from 1/4/2022 wherein the order passed by the learned transfer pricing officer is also included and in sub clause (iii) the order under section 92CA by the transfer pricing officer is included. Therefore, even if such order is passed by the transfer pricing Officer prior to 1/4/2022

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

1 (a) to section 263 of the Act is also amended with effect from 1/4/2022 wherein the order passed by the learned transfer pricing officer is also included and in sub clause (iii) the order under section 92CA by the transfer pricing officer is included. Therefore, even if such order is passed by the transfer pricing Officer prior to 1/4/2022