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4,835 results for “transfer pricing”+ Section 9(1)clear

Sorted by relevance

Delhi5,221Mumbai4,835Bangalore1,953Chennai1,043Kolkata881Ahmedabad763Pune751Hyderabad737Karnataka517Jaipur440Surat312Chandigarh293Indore275Cochin236Visakhapatnam139Rajkot128SC118Telangana89Cuttack85Nagpur84Raipur71Calcutta68Lucknow67Amritsar53Guwahati38Jodhpur35Dehradun33Agra32A.K. SIKRI ROHINTON FALI NARIMAN16Jabalpur14Ranchi14Varanasi12Panaji12Kerala11Rajasthan11Allahabad11Patna10Orissa7Punjab & Haryana3DIPAK MISRA V. GOPALA GOWDA1MADAN B. LOKUR S.A. BOBDE1S.B. SINHA MARKANDEY KATJU1A.K. SIKRI N.V. RAMANA1D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1

Key Topics

Section 143(3)64Addition to Income52Disallowance38Transfer Pricing30Section 115J28Section 271(1)(c)23Section 25022Section 4022Deduction22

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 133(6)Section 92D

1 Transfer Pricing Adjustment relating to Data Processing\nServices Rs. 9,01,18,424 and Software Services Rs. 5,95,81,859\nAdjudicated relying on charts enclosed at Page 48 to 51 and 87 to\n91 of the Supplementary Paperbook\n1.1. On the facts and in the circumstances of the case, the learned\nTransfer Pricing Officer ('TPO') and the learned

DCIT, CIRCLE 3(4), MUMBAI, MUMBAI vs. TATA CONSULTANCY SERVICES LIMITED, MUMBAI

ITA 2243/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19
Section 92CSection 92C(3)

9,96,61,577 being the 'Singapore tax\npaid as defined under Article 25 (3) of the of the Double Tax Avoidance Agreement\nbetween India and Singapore.\nGrounds related to Transfer Pricing:\n2 Transfer pricing adjustments/additions/variations,\n2.1 The Id. CIT (A) erred in law, on facts and in circumstances of the case in not\ndeleting the transfer pricing adjustments/additions/variations made

Showing 1–20 of 4,835 · Page 1 of 242

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Section 14A20
Section 56(2)(x)20
Section 92C19

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)

9(3)(1), Mumbai Assesseeby : Shri Dhanesh Bafnaa/w Ms. Hirali Desai Revenue by : Shri Jayant Kumar Date of Hearing – 26.04.2018 Date of Order – 23.07.2018 O R D E R PER SAKTIJITDEY, J.M. Aforesaid appeal by the assessee is directed against the assessment order dated 31st January 2017, passed under section 143(3) r/w section 144C(13) of the Income

ILJIN ELECTRIC CO. LTD,MUMBAI vs. DCIT (IT) CIR 2(2)(1), MUMBAI

In the result, appeal for A

ITA 1023/MUM/2015[2011-12]Status: DisposedITAT Mumbai14 Oct 2016AY 2011-12

Bench: Shri Jason P. Boaz, Accoutant Member & Shri Saktijit Dey

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Jasbir Chauhan
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 234D

transfers of capital assets/property situate in India. To do so, would amount to changing the content and ambit of Section 9(1)(i).” 87. In the present case also, Linde has contended that it being nonresident is not liable to pay tax in India and the sweep of Section 9(1) of the Act cannot be extended to income whch

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

1) of the act. Accordingly ground number 2 of the appeal of the AO is dismissed. 0104. Accordingly, for assessment year 2009–10, appeal of the assessee is partly allowed and appeal of the Assessing Officer is dismissed. For A.Y. 2010–11 0105. ITA Nos. 3811 & 5227/Mum/2016 0106. Assessee has preferred ITA number 3811/M/2016 for assessment year 2000 – 11 against

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

9. We have considered rival submissions and perused materials on record. As could be seen from Page–18 of the Transfer Pricing Officer’s order, he has applied certain filters for selecting comparables from the data bases. One of the filter applied by the Transfer Pricing Officer is companies whose on–site revenue is more than 60% of the export

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)

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 of listed Indian equities; (b) Investment advisory/support services in respect of strategic (unlisted) investments and (c) Investment banking services, provided by the Appellant to its overseas associated Enterprises

SHELL INFORMATION TECHNOLOGY INTERNATIONAL BV,MUMBAI vs. DCIT (IT) 4(1)(2), MUMBAI

In the result, both the appeals of assessee are allowed

ITA 1203/MUM/2015[2010-11]Status: DisposedITAT Mumbai16 Nov 2017AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri G. Manjunatha, Am

For Appellant: Niraj Sheth, ARFor Respondent: Samuel Darse, DR
Section 143(3)Section 90

section 14 of the ‘Copyright Act’ is applicable as held by the learned CIT(A); and is also is evident from the terms of MSA, because no such rights has been given by the assessee to the IT Service providers

SHELL INFORMATION TECHNOLOGY INTERNATIONAL BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, both the appeals of assessee are allowed

ITA 2204/MUM/2014[2009-10]Status: DisposedITAT Mumbai16 Nov 2017AY 2009-10

Bench: Sri Mahavir Singh, Jm & Sri G. Manjunatha, Am

For Appellant: Niraj Sheth, ARFor Respondent: Samuel Darse, DR
Section 143(3)Section 90

section 14 of the ‘Copyright Act’ is applicable as held by the learned CIT(A); and is also is evident from the terms of MSA, because no such rights has been given by the assessee to the IT Service providers

M/S. SATELITE TELEVISION ASIAN REGION LTD.,MUMBAI vs. DDIT (INT. I.T) 2(1), MUMBAI

In the result, all the appeals by the assessee and the Revenue are partly

ITA 6604/MUM/2004[2001-2002]Status: DisposedITAT Mumbai05 Oct 2018AY 2001-2002

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm

Section 195Section 197Section 40Section 9Section 9(1)(i)

9(1)(vi) of the Act. Therefore, no disallowance of expenditure under Section 40(a)(vi) of the Act, can be made in the present facts. (g) In the above view, as it is a self evident position from the reading Section 40(a)(i) of the Act, no substantial question of law. Thus, question (a) not entertained

RELIANCE JIO INFOCOMM USA INC.,TEXAS vs. DCIT (IT) 4 (1) (1), MUMBAI

In the result appeal filed by the assessee stands allowed

ITA 2991/MUM/2023[2020-21]Status: DisposedITAT Mumbai17 Apr 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Bijayananda Pruseth ()

Section 143(2)Section 143(3)Section 144C(5)Section 153Section 9(1)(vi)Section 9(1)(vii)

section 9(1)(vi) vide Finance Act, 2012 twr.e.f 1-6-1976: "Explanation 5-For the removal of doubts, it is hereby clarified that the royalty includes and has always included consideration in respect of any right property or information, whether or not- at the port of such right property or information in with the payer, right property formation