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9 results for “transfer pricing”+ Section 6(2)clear

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Key Topics

Section 2603Comparables/TP3Section 260A2Section 1662Transfer Pricing2

PRINCIPAL COMMISSIONER OF INCOME TAX 1 vs. INDUSTRIAL PROMOTION AND INVESTMENT CORPORATION OF ORISSA LTD.

Accordingly, the learned appellate authority has rightly dismissed the

ITA/15/2021HC Orissa31 Jan 2023

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical

BARUNEI ROLLER FLOUR MILL (P) LTD. vs. COMMISSIONER OF INCOME TAX (APPEALS) 1

In the result, the award of the maximum uniform rate for the

ITA/1/2022HC Orissa03 Nov 2023

Bench: DR. JUSTICE B.R.SARANGI (ACJ),MR. JUSTICE MURAHARI SRI RAMAN

price of the land and building, standing crops, trees, cultivation etc., whereafter, the Collector vide letter dated 31.10.2003, had sent the application to the Special Judicial Officer for disposal. The Collector he submitted, has stated in the Reference that the amount of compensation was determined Page 43 of 99 on the basis of fair market value, but however

ACIT, CIRCLE 1(2) vs. M/S. SERAJUDDIN AND CO.

The appeal is disposed of with liberty as prayed for by the learned counsel for

ITA/43/2022HC Orissa15 Mar 2023

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

Section 260

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 12.10.2020 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.Nos.160 and 211/Bang/2016 for the assessment year 2011-12, raising the following substantial questions of law: “1. Whether

PRINCIPAL COMMISSIONER OF INCOME TAX-1,BHUBANESWAR vs. SEKHAR KUMAR MOHAPATRA

ITA/9/2024HC Orissa15 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

For Appellant: Mr. Ajit Kumar, Sr. AdvocateFor Respondent: Mr. Prashant Vidyarthy, Sr. Panel Counsel
Section 164Section 42

2 of 2018 and the learned Special Judge took cognizance vide order dated 19.11.2018 against 6 accused persons namely Pradeep Kumar, Rajendra Kumar, Nand Lal HUF, Shyamal Chakrabarty, Dharmendra Kumar Dhiraj and Naresh Kumar Kejriwal. 5. After investigation, the provisional attachment order (PAO) No. 4/2018 dated 20.02.2018 was issued by the ED under Section 5(1) of the PMLA whereas

M/S.SHEETAL REAL vs. INCOME TAX OFFICER

In the result, the appeal fails and the substantial questions of law

ITA/83/2010HC Orissa08 Feb 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 260ASection 372A

2) was issued on 20th October, 2006 subsequently, notice under Section 142(1) was issued. The assessee is in the business of manufacture and sale of plywood and related products having its registered office in Kolkata and four regional offices and seventeen branches. Several issues were discussed with the assessee and the assessment was completed under Section

PR.COMMISSIONER OF INCOME TAX,BHUBANESWAR vs. M/S.UTKAL ALUMINA INTERNATIONAL LTD.

ITA/10/2017HC Orissa04 Dec 2019

Bench: MR. JUSTICE K. S. JHAVERI (CJ),MR. JUSTICE K.R.MOHAPATRA

6. Regarding carrying the mentioned development works in the construction of the building. DW-2 7. Ration card of the Plaintiff DW-2 8. Ration card of the Defendant DW-2 Signed By:SAVITA PASRICHA Signing Date:09.01.2026 16:51:13 Signature Not Verified RFA (OS) 05/2017 and connected matters Page 17 of 43 9. Letter to the Defendant

PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. INDIAN METALS AND FERRO ALLOYS LTD.

In the result, the substantial questions of law (i)

ITA/10/2021HC Orissa30 Jan 2023

Bench: : The Hon’Ble Acting Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 3Rd April, 2023 Appearance : Mr. Soumen Bhattacharjee, Adv. ...For The Appellant Mr. Asim Choudhury, Adv. Mr. Soham Sen, Adv. ...For The Respondent. The Court : This Appeal Filed By The Revenue Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated October 17, 2018 Passed By The Income Tax Appellate Tribunal, “C” Bench, Kolkata (The Tribunal) In Ita No.524/Kol/2017 For The Assessment Year 2012-13. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration:

Section 260ASection 32Section 92C

Transfer Pricing in respect of International Transactions” by TPO relied upon the decision in assessee’s own case for Assessment Year 2007-08 and 2008-09? 3 (v) Whether on the facts and circumstances of the case and on law Learned Income Tax Appellate Tribunal was justified in granting relief to the assessee on addition

MAHESWAR PANDA vs. I.T.O., WARD-2(1)

ITA/48/2023HC Orissa15 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

Section 166

transferring the burden of paying the amount of compensation from respondent no.1-Insurance Company to the appellants herein.” 27. In the present matter, it is not the case that the victim himself was sitting on the mudguard of the tractor, rather he was sitting in the trolley which was used for the agricultural purpose as they were carrying the rice straw

PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.AHINSA VINIMAY PVT.LTD.

ITA/132/2018HC Orissa05 Apr 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 260

2) Whether, on the facts and in the circumstances of the case and in law, the Tribunal was right in seeking comparability in imposing condition beyond law whereas the requirement of law is to acknowledge only those differences that are likely to materially affect the margin? 3) Whether, on the facts and in the circumstances of the case