BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

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.

1,837 results for “transfer pricing”+ Section 57clear

Sorted by relevance

Delhi2,167Mumbai1,837Bangalore699Karnataka620Chennai395Ahmedabad310Hyderabad254Kolkata244Jaipur222Pune217Chandigarh184Cochin136Indore131Surat111Visakhapatnam65Rajkot58Lucknow55Calcutta55Telangana51SC38Raipur37Nagpur33Cuttack31Agra28Jodhpur16Dehradun14Amritsar13Ranchi8Varanasi5Allahabad4Guwahati4A.K. SIKRI ROHINTON FALI NARIMAN3Orissa3Rajasthan3Jabalpur2S.B. SINHA MARKANDEY KATJU1Andhra Pradesh1Punjab & Haryana1Panaji1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 143(3)72Addition to Income66Disallowance43Section 14A30Section 6826Transfer Pricing25Section 115J23Deduction18Section 10(38)17

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

Transfer Pricing Officer has not benchmarked this particular transaction by aggregating it with other ITES, we are inclined to restore the issue to the Assessing Officer for undertaking the necessary exercise of benchmarking the transaction by aggregating with other ITES and determine the arm's length price by applying the average margin of the comparables selected under the ITES segment

Showing 1–20 of 1,837 · Page 1 of 92

...
Double Taxation/DTAA15
Exemption15
Depreciation15

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)

Transfer Pricing Officer under section 133(6) was furnished to the assessee, however, assessee did not raise any objection. Learned Departmental Representative submitted, even if there is some minor / narrow difference in functionality of the company but it has no impact on the bench marking of the transaction under TNMM. 56. We have considered the submissions of the parties

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)

57. Before learned DRP, the assessee challenged selection / rejection of certain comparables. After considering the submissions of the assessee, learned DRP accepted R.S. Software Ltd., selected by the assessee as a comparable and rejected FCS Software Solutions Ltd., selected by the Transfer Pricing Officer. 58. Before us, the learned Sr. Counsel submitted, though in the grounds raised the assessee

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)

section 92C 8 ITA 6081/Mum/2018 r.w.r.10B, the arms length price in relation to an international transaction shall be determined by adopting any one method thereunder and not by adopting two methods as the most appropriate method. The assessee has also argued for not adopting as most appropriate method, as per which, the price at which finished goods are exported

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

section 144C(13) of the Income Tax Act, 1961 (for short "the Act") in pursuance to the directions of the Dispute Resolution Panel–III (DRP), Mumbai. 2. Since all these appeals pertain to the same assessee involving common issues arising out of identical set of facts and circumstances, therefore, as a matter of convenience, these appeals were heard together

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

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

57,112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With

M/S. MERCATOR LTD,MUMBAI vs. THE DY CIT 5(2), MUMBAI

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

ITA 7278/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Dec 2022AY 2010-11

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

For Appellant: Mr.Nikhil Tiwari.ARFor Respondent: Mr.KrishnaKumarMishra.DR
Section 143(3)Section 14ASection 250

57 [hereinafter referred to as the 'CIT(A)] under section 250 of the Income-tax Act, 1961 (hereinafter referred to as the 'Act') in respect of the order passed by the Deputy Commissioner of Income-tax-Range 5(2), Mumbai (hereinafter referred to as the 'AO') under section 143(3) r.w.s. 144C of the Act, on the following grounds which

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)

Transfer Pricing Officer and accordingly, assessee is in further appeal before us. 8.2 Notably, as the orders of the lower authorities reveal, the principal plea of the assessee was that furnishing of a corporate guarantee on behalf of the associated enterprise is not to be construed as an ‘international transaction’ within the meaning of section 92B of the Act. Before

SOLAR TURBINES INDIA P.LTD,MUMBAI vs. DCIT 15(3)(2), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 1075/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2017AY 2011-12

Bench: Shri Rajendra & Shri Saktijit Deyआयकर अपीऱ सं. / Ita No. 1075/Mum./2016 (निर्धारण वषा / Assessment Year : 2011–12) Solar Turbines India Pvt. Ltd. (Formerly Known As Turbomach India P. Ltd.), 401, 402, 403, 4Th Floor ……………. Appellant Powai Plaza, Hiranandani Business Park Powai, Mumbai 400 076 Pan – Aabct7422R V/S Dy. Commissioner Of Income Tax Circle–15(3)(2), Aayakar Bhawan ……………. Respondent 101, M.K. Road, Mumbai 400 020 निर्धाररती की ओर से / Assessee By : Shri Arvind Sonde A/W Shri Ketan Ved रधजस्व की ओर से / Revenue By : Shri N.K. Chand सुिवधई की तधरीख / आदेश घोषणध की तधरीख / Date Of Hearing – 05.10.2016 Date Of Order – 02.01.2017 आदेश / Order शक्तिजीि दे, न्याययक सदस्य के द्वारा / Per Saktijit Dey, J.M.

For Appellant: Shri Arvind Sonde a/wFor Respondent: Shri N.K. Chand
Section 133(6)Section 143(3)Section 234ASection 271(1)(c)

section 234A, 234B and 234D of the Act. Relief Relief Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the learned DRP be deleted. The Appellant prays that the addition made by the learned AO and TPO and upheld by the learned

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

57,180/- of income as per return of income filed on 30th August, 2009. The learned Assessing Officer has made an adjustment of 02. ₹3,15,47,177/- as per order of the learned Transfer Pricing Officer, Circle 11(9), Mumbai, (the learned Transfer Pricing Officer) passed under Section

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

57,180/- of income as per return of income filed on 30th August, 2009. The learned Assessing Officer has made an adjustment of 02. ₹3,15,47,177/- as per order of the learned Transfer Pricing Officer, Circle 11(9), Mumbai, (the learned Transfer Pricing Officer) passed under Section