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.

1,934 results for “transfer pricing”+ Section 80clear

Sorted by relevance

Mumbai1,934Delhi1,870Bangalore711Karnataka500Ahmedabad439Chennai418Kolkata334Hyderabad285Pune285Jaipur242Surat215Chandigarh172Indore140Cochin123Calcutta59Visakhapatnam48Raipur46Telangana40Cuttack39SC37Rajkot36Lucknow29Nagpur29Agra23Guwahati22Jodhpur20Amritsar18Ranchi10Dehradun9Varanasi5Rajasthan5Allahabad4Panaji3Jabalpur2Orissa2Kerala2Patna1Andhra Pradesh1T.S. THAKUR ROHINTON FALI NARIMAN1A.K. SIKRI N.V. RAMANA1Punjab & Haryana1

Key Topics

Section 143(3)86Addition to Income65Section 14A48Disallowance45Transfer Pricing26Deduction22Section 115J19Section 143(2)15Section 69C14

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

section 133(6) of the Act the company had stated that, though, it has shown nil on–site revenue during the year, however, the reason for doing so is because it was not able to bifurcate its revenue between on–site and off–shore activities. That being the case, the company cannot be treated as comparable. The learned Sr. Counsel

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

Showing 1–20 of 1,934 · Page 1 of 97

...
Section 6813
Double Taxation/DTAA13
Exemption13

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 in Page–37 of his order submitted, assessee also provides high end information technology enabled services, hence, assessee’s objections should not be accepted. 67. We have considered the submissions of the parties and perused the material available on record. We have noted that the Tribunal, Bangalore Bench, in Symphony Marketing Solutions India Pvt. Ltd. (supra), after

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)

section 10A / 10AA in respect of IPSA income following the direction of the Tribunal and DRP as referred to above. This ground is allowed. 47. Grounds no.24, 25, 26 and 27 are not pressed, hence, dismissed. 48. In view of our decision in ground no.23, the additional grounds being grounds no.28 and 29, have become infructuous, hence, dismissed

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 234B and 234D of the Act. 70. Levy of interest being consequential is not required to be adjudicated at this stage. 71. In the result, appeal is partly allowed. ITA no.1754/Mum./2014 Revenue’s Appeal – A.Y. 2009–10 72. The grounds raised by the Revenue are corresponding to grounds no.1 and 2 of ITA no.990/Mum./2014. In view

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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 adjustment the learned Assessing Officer made the following disallowances; Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 i. Deduction under Section 35(2AB) of the Act was reduced by ₹7,54,500/- on account of different in form no. 3CL. ii. The assessee has earned exempt income of ₹80

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)

80% or more of the cost stands written-off in the first 16 year itself against the revenues generated from the telecast in India. Thus, in our considered opinion, the Transfer Pricing Officer has not discharged his burden to demonstrate how the transaction with associate enterprise be considered as dubious. 7.5 The unsustainability of the approach of the Transfer Pricing

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

transfer pricing adjustment relating to mark–up on reimbursement of expenses at ` 21,99,60,689. 36 Viacom 18 Media Pvt. Ltd. 80. Having heard both the parties and having perused the material on record, we find that related facts and circumstances of the issue raised by the Revenue is mutatis mutandis and materially identical to the issue decided

SAF YEAST COMPANY P.LTD,MUMBAI vs. ASST CIT CEN CIR 40, MUMBAI

In the result the appeal of the assessee for AY 2009-10 is partly allowed

ITA 1875/MUM/2014[2009-10]Status: DisposedITAT Mumbai16 May 2018AY 2009-10

Bench: Shri B.R. Baskaran (Am)& Shri Pawan Singh (Jm)

Section 80I

section 80-IA - Whether price charged by assessee while transferring manufactured electricity from C.P.P. unit to its other unit including

M/S. INDIA MEDTRONICS PVT.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(2),, BARODA

In the result, similarly the Assessee’s appeal is partly allowed

ITA 480/AHD/2011[2005-06]Status: DisposedITAT Mumbai30 Sept 2022AY 2005-06

Bench: Shri Amit Shukla & Shri Gagan Goyal

For Appellant: Sh. Rajan R. Vora with Sh. Nikhil TiwariFor Respondent: Dr. Yogesh Kamath/ Akhtar Hussain Ansari
Section 234BSection 271Section 274Section 92C

Transfer Pricing Officer to delete the addition on account of excessive purchase price as it is already benchmarked once under TNMM/RPM, as under 69. However, learned Commissioner (Appeals), inadvertently dismissed the ground, whereas it was to be allowed following DRP direction. Hence, the based on the above order, adjustment on account of excessive purchase price amounting

DCIT CIR 3(1), MUMBAI vs. GLOBE OP FINANCIAL SERVICES (INDIA) P. LTD, MUMBAI

In the result, Department’s appeal is partly allowed for statistical purposes

ITA 1610/MUM/2011[2005-06]Status: DisposedITAT Mumbai13 Jun 2016AY 2005-06

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri Saurabh Soparkar a/wFor Respondent: Shri Sambit Mishra
Section 92C

section 143(3) adding the amount of ` 2,62,84,830. Being aggrieved of the assessment order so passed, the assessee preferred appeal before the first appellate authority. 4. The learned Commissioner (Appeals), after considering the submissions of the assessee and on a perusal of the material on record, accepted the contention of the assessee that two companies selected