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59 results for “transfer pricing”+ Section 109clear

Sorted by relevance

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Key Topics

Section 143(3)64Addition to Income43Section 12A41Section 92C(3)25Section 1125Section 10(20)24Transfer Pricing22Section 26317TDS14Deduction

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

ITA 738/PUN/2017[2011-12]Status: DisposedITAT Pune30 Aug 2021AY 2011-12

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Sangram Gaikwad
Section 132Section 143(3)Section 153ASection 92C

109. M/s. Sava Medica Ltd. 8. The assessee assailed the draft order before the DRP on several issues. The DRP called for comments/reports from the TPO/AO on certain aspects and also the comments of the assessee. After entertaining the entire gamut of the material, the DRP inter alia came to hold that: - The TPO was not justified in holding that

Showing 1–20 of 59 · Page 1 of 3

13
Section 144C(8)12
Section 201(1)12

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

ITA 739/PUN/2017[2012-13]Status: DisposedITAT Pune30 Aug 2021AY 2012-13

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Sangram Gaikwad
Section 132Section 143(3)Section 153ASection 92C

109. M/s. Sava Medica Ltd. 8. The assessee assailed the draft order before the DRP on several issues. The DRP called for comments/reports from the TPO/AO on certain aspects and also the comments of the assessee. After entertaining the entire gamut of the material, the DRP inter alia came to hold that: - The TPO was not justified in holding that

M/S. SAVA MEDICA LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, the appeal for the A

ITA 740/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2021AY 2013-14

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita Nos.738, 739 & 740/Pun/2017 िनधा"रण वष" / Assessment Years : 2011-12, 2012-13 & 2013-14

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Sangram Gaikwad
Section 132Section 143(3)Section 153ASection 92C

109. M/s. Sava Medica Ltd. 8. The assessee assailed the draft order before the DRP on several issues. The DRP called for comments/reports from the TPO/AO on certain aspects and also the comments of the assessee. After entertaining the entire gamut of the material, the DRP inter alia came to hold that: - The TPO was not justified in holding that

MERCEDEZ-BENZ INDIA PRIVATE LTD.,,PUNE vs. DEPUTY COMMSSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed as indicated above and all appeals of Revenue and Cross Objection of assessee are dismissed

ITA 380/PUN/2015[2010-11]Status: DisposedITAT Pune31 Jul 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am

Section 143(3)

transfer pricing adjustments/additions/variations made by the learned AO under section 143(3) of the Act should be deleted. Your Honours would appreciate that additional ground can be raised at appellate stage, if the facts in connection with the issues raised, are on record. In support of the said proposition, the Appellant relies on the following judicial precedents in this regard

MERCEDES - BENZ INDIA PRVIATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed as indicated above and all appeals of Revenue and Cross Objection of assessee are dismissed

ITA 514/PUN/2014[2009-10]Status: DisposedITAT Pune31 Jul 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am

Section 143(3)

transfer pricing adjustments/additions/variations made by the learned AO under section 143(3) of the Act should be deleted. Your Honours would appreciate that additional ground can be raised at appellate stage, if the facts in connection with the issues raised, are on record. In support of the said proposition, the Appellant relies on the following judicial precedents in this regard

DEPUTY COMMISSIONER OF INCOME-TAX vs. MERCEDES BENZ INDIA PVT. LTD.,, PUNE

In the result, all the appeals of assessee are allowed as indicated above and all appeals of Revenue and Cross Objection of assessee are dismissed

ITA 566/PUN/2014[2009-10]Status: DisposedITAT Pune31 Jul 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am

Section 143(3)

transfer pricing adjustments/additions/variations made by the learned AO under section 143(3) of the Act should be deleted. Your Honours would appreciate that additional ground can be raised at appellate stage, if the facts in connection with the issues raised, are on record. In support of the said proposition, the Appellant relies on the following judicial precedents in this regard

ASSITANT COMMISSIONER OF INCOME-TAX vs. MERCEDES BENZ INDIA PVT. LTD.,, PUNE

In the result, all the appeals of assessee are allowed as indicated above and all appeals of Revenue and Cross Objection of assessee are dismissed

ITA 486/PUN/2015[2010-11]Status: DisposedITAT Pune31 Jul 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am

Section 143(3)

transfer pricing adjustments/additions/variations made by the learned AO under section 143(3) of the Act should be deleted. Your Honours would appreciate that additional ground can be raised at appellate stage, if the facts in connection with the issues raised, are on record. In support of the said proposition, the Appellant relies on the following judicial precedents in this regard

ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE vs. MERCEDES - BENZ INDIA PVT. LTD.,, PUNE

In the result, all the appeals of assessee are allowed as indicated above and all appeals of Revenue and Cross Objection of assessee are dismissed

ITA 534/PUN/2016[2011-12]Status: DisposedITAT Pune31 Jul 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am

Section 143(3)

transfer pricing adjustments/additions/variations made by the learned AO under section 143(3) of the Act should be deleted. Your Honours would appreciate that additional ground can be raised at appellate stage, if the facts in connection with the issues raised, are on record. In support of the said proposition, the Appellant relies on the following judicial precedents in this regard

M/S EATON POWER QUALITY P.LTD.,PUNE vs. ACIT, PUNE

In the result, the appeal of assessee in ITA No

ITA 119/PUN/2013[2008-09]Status: DisposedITAT Pune11 Sept 2018AY 2008-09

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vishal KalraFor Respondent: Shri Rajeev Kumar
Section 143(3)

109 to 112 support services August 21, 2008 of paper book) August 20, 2008 August 15, 2008 September 21, 2007, Set up and re-set of Keyfob August 29, 2007, PIN September 07, 2007, (Refer Page 119 to 120, September 03, 2007, 131 to 133 of paper August 29, 2007 book) 3.6 Despite the aforementioned evidences, the AO/DRP/TPO rejected

M/S. EATON POWER QUALITY PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of assessee in ITA No

ITA 1373/PUN/2014[2007-08]Status: DisposedITAT Pune11 Sept 2018AY 2007-08

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vishal KalraFor Respondent: Shri Rajeev Kumar
Section 143(3)

109 to 112 support services August 21, 2008 of paper book) August 20, 2008 August 15, 2008 September 21, 2007, Set up and re-set of Keyfob August 29, 2007, PIN September 07, 2007, (Refer Page 119 to 120, September 03, 2007, 131 to 133 of paper August 29, 2007 book) 3.6 Despite the aforementioned evidences, the AO/DRP/TPO rejected

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. UNDERCARRIAGE AND TRACTOR PARTS PRIVATE LIMITED, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

ITA 839/PUN/2024[2015-16]Status: DisposedITAT Pune07 Jan 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Tanzil TadvekarFor Respondent: Shri Pawan Bharati
Section 271GSection 92CSection 92DSection 92D(3)

section 92D. Perusal of Transfer pricing study report shows that the appellant has adopted CUP as most appropriate method for all the transactions with the AEs. Following are the details given by the appellant in its TP study report on page 26 and 39. 3 ITA No.839/PUN/2024, AY 2015-16 Sr. No. Type of Amount Rs. Criteria Transaction 1 Purchase

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1066/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1065/PUN/2017[2010-11]Status: DisposedITAT Pune27 Jun 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1063/PUN/2017[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1062/PUN/2017[2007-08]Status: DisposedITAT Pune27 Jun 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

section 143(3) r.w.s. 144C(13) of the Act r.w.s. 153A of the Act noted the directions of DRP, which reduced the transfer pricing adjustment to ₹ 29,78,900/- as against ₹ 91,21,109

GOODYEAR SOUTH ASIA TYRES PRIVATE LTD.,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, AURANGABAD

In the result, both the appeals of assessee are allowed as indicated above

ITA 1068/PUN/2016[2011-12]Status: DisposedITAT Pune04 Sept 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.1068/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

For Appellant: Shri Dhanesh Bafna and Ms. Chandni ShahFor Respondent: Ms. Amrita Misra, CIT
Section 143(3)Section 92C

109/-. The case of assessee was selected for scrutiny. The Assessing Officer noted that the assessee had entered into international transactions with its associated enterprises and made reference under section 92CA(1) of the Act to the Transfer Pricing

GOODYEAR SOUTH ASIA TYRES PRIVATE LIMITED,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, AURANGABAD

In the result, both the appeals of assessee are allowed as indicated above

ITA 684/PUN/2017[2012-13]Status: DisposedITAT Pune04 Sept 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.1068/Pun/2016 यििाारण वषा / Assessment Year : 2011-12

For Appellant: Shri Dhanesh Bafna and Ms. Chandni ShahFor Respondent: Ms. Amrita Misra, CIT
Section 143(3)Section 92C

109/-. The case of assessee was selected for scrutiny. The Assessing Officer noted that the assessee had entered into international transactions with its associated enterprises and made reference under section 92CA(1) of the Act to the Transfer Pricing

SPECTRAFORCE TECHNOLOGIES (INDIA) PRIVATE LIMITED,PUNE vs. ACIT, CIRCLE 5, PUNE, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes as per terms indicated hereinabove

ITA 2853/PUN/2024[AY 2021-22]Status: DisposedITAT Pune18 Jul 2025

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri S. Raghunathan and Shri Abhiroop Bhargav KFor Respondent: Shri Prakash L. Pathade
Section 143(3)Section 92C(3)

section 92C(3) and Rule 10B(3) are satisfied in the present case. 8. That on the facts and circumstances of the case and in law, the Ld. AO/Ld. TPO/DRP has erred in enhancing the income of Appellant by Rs. 2,90,89,437 while holding that the Appellant's international transaction pertaining to provision of Staff 8 Augmentation Service