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5 results for “transfer pricing”+ Section 80A(6)clear

Sorted by relevance

Mumbai72Bangalore36Ahmedabad36Delhi29Jaipur12Amritsar7Hyderabad7Pune5Nagpur3Calcutta3Chennai2Karnataka2Kolkata2Rajkot2SC1Indore1

Key Topics

Section 115J9Section 10B8Section 143(3)6Section 80G4Section 80I4Section 92C4Transfer Pricing4Deduction4Addition to Income4Comparables/TP

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

ITA 2033/PUN/2019[2015-16]Status: DisposedITAT Pune30 May 2024AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 153Section 153(1)Section 40A(2)(b)Section 92BSection 92C

80A; (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter VI-A or section 10AA, to which provisions

4
Disallowance3
Section 412

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

ITA 1994/PUN/2024[2020-21]Status: DisposedITAT Pune06 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80

transfer pricing adjustments ought not be made to the computation of book profits under section 115JB of the Act. 7. Non grant of deduction under section 80-IAB on income from other sources and capital gains earned during the subject year The Hon’ble. DRP / NFAC / Ld.AO has erred in not granting a deduction under section

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE vs. HSBC SOFTWARE DEVELOPMENT (INDIA) PRIVATE LIMITED,, PUNE

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

ITA 2348/PUN/2017[2011-12]Status: DisposedITAT Pune30 Aug 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Respondent: Shri Percy Jal Pardiwalla
Section 10A(7)Section 10BSection 10B(7)Section 143(3)Section 80I

pricing rules for domestic transactions. It is worth noting that neither the provisions of section 80IA(8) and 80IA(10) have application to the international transactions nor the Explanation appended to section 80IA as amended by the Finance Act, 2012. In the present case, indisputably, the transactions between the assessee company and its AE are international transactions as defined

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE vs. HSBC SOFTWARE DEVELOPMENT (INDIA) PVT.LTD,, PUNE

In the result, CO of assessee is allowed and the appeals of Revenue are dismissed

ITA 1464/PUN/2017[2010-11]Status: DisposedITAT Pune30 Aug 2022AY 2010-11

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Respondent: Shri Percy Jal Pardiwalla
Section 10A(7)Section 10BSection 10B(7)Section 143(3)Section 80I

pricing rules for domestic transactions. It is worth noting that neither the provisions of section 80IA(8) and 80IA(10) have application to the international transactions nor the Explanation appended to section 80IA as amended by the Finance Act, 2012. In the present case, indisputably, the transactions between the assessee company and its AE are international transactions as defined

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

ITA 1571/PUN/2024[2020-21]Status: DisposedITAT Pune04 Apr 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri R D OnkarFor Respondent: Shri Ramnath P Murkunde
Section 143(1)(a)Section 143(3)Section 154Section 37Section 37(1)Section 41Section 41(1)Section 80ASection 80G

Transfer Pricing Officer (TPO) for determination of the arm's length price of the international transactions who proposed Nil adjustment. However, the Assessing Officer took Rs.1,64,17,30,653/- as variation with respect to the TP adjustment. The Assessing Officer thereafter passed the draft assessment order determining the total income at Rs.338,51,08,520/- by making certain other