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15 results for “transfer pricing”+ Section 145clear

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Key Topics

Section 808Section 37(1)5Section 34Exemption4Section 653Section 473Section 2(1)2Section 1452Section 572Penalty

M/S JINDAL EQUIPMENT LEASING CONSULTANCY SERVICES LTD. vs. COMMISSIONER OF INCOME TAX

Appeals stand disposed of in the aforesaid terms

C.A. No.-000152-000152 - 2026Supreme Court09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

price below cost is allowed even though such loss has not been realised actually. 30. At this stage, we need to emphasise once again that the above system of commercial accounting can be superseded or modified by legislative enactment. This is where Section 145(2) comes into play. Under that section, the Central Government is empowered to notify from time

M/S. SANJEEV WOOLEN MILLS vs. COMMNR. OF INCOME TAX, MUMBAI

The appeal is dismissed with no order as to costs

C.A. No.-006735-006736 - 2003
2
Addition to Income2
Deduction2
Supreme Court
24 Nov 2005
For Respondent: Commissioner of Income-tax, Mumbai
Section 80

price whichever is the lower, and it is now generally accepted as an established rule of commercial practice and accountancy." In A.L.A. Firm vs. C.I.T. [1991] Vol.189 I.T.R. (S.C.) page 285, the Court said that as against the valuation of the stock at cost or market whichever is lower, valuation of the closing stock at the market value will invariably

UCO BANK vs. COMM.OF INCOME TAX, WEST BENGAL

C.A. No.-000235-000235 - 1996Supreme Court13 May 1999
For Respondent: COMMISSIONER OF INCOME-TAX, WEST BENGAL
Section 256(1)Section 263

145 of the Income-tax Act, 1961, income chargeable under the head "profits and gains of business or profession or income from other sources" shall be computed in accordance with the method of accounting regularly employed by the assessee; provided that in a case where the accounts are correct and complete but the method employed is such that

THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS

C.A. No.-000262-000262 - 2026Supreme Court15 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

transfer of the CGP share and not by virtue of various clauses of SPA. In a case like the present one, where the structure has existed for a considerable length of time generating taxable revenues right from 1994 and where the court is satisfied that the transaction satisfies all the parameters of “participation in 66 investment” then in such

COMMR.OF INCOME TAX,NEW DELHI vs. M/S REALEST BUILDERS & SERVICES LTD

Appeal is dismissed in terms of our above order in Civil Appeal

C.A. No.-003378-003378 - 2008Supreme Court07 May 2008
Section 145

price paid by the assessee for the individual plot to DLF and the profits worked out on that basis. The working shows that profit is worked out on sale of individual plots. According to the assessee, since there was no transfer of right, title and interest upto the date of execution of conveyance, income did not accrue to the assessee

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. AHMEDABAD URBAN DEVELOPMENT AUTHORITY

C.A. No.-021762-021762 - 2017Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

145 H. Application of interpretation................................................................................................................... 146 4 1. Leave granted in all matters where leave has not already been granted. C.A. No. 21762/2017 (Assistant Commission of Income Tax, Exemptions v. Ahmedabad Urban Development Authority) is taken as the lead matter. 2. Religious and charitable trusts have existed in one form or the other, tracing their origins to the instinct

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-008733-008734 - 2018Supreme Court02 Mar 2021

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

transfer to the copy/copies any copyright or other marking on the Software or Documentation. d) not use the Software or Documentation for any other purpose than permitted in this Article 20, License or sell or in any manner alienate or part with its possession. e) not use or transfer the Software and/or the Documentation outside India without the written consent

TEA ESTATE INDIA (P) LTD. vs. COMMISSIONER OF INCOME-TAX

- 0Supreme Court26 Apr 1976
For Respondent: COMMISSIONER OF INCOME-TAX
Section 2Section 2(1)Section 2(3)

145 1976 SCC (4) 446 CITATOR INFO : R 1976 SC2469 (10) R 1977 SC 489 (22) RF 1977 SC 560 (11) RF 1988 SC1453 (33) ACT: Income Tax Act 1922-Sec. 2(1), 2(4A), 2(6C), 2(3)(8) find 2(6A) C. Income Tax Rules 1922-Rules 23 and 24-Dividends- Accumulated profits-Composite business activity including agricultural

RAMNATH AND CO. vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-002506-002509 - 2020Supreme Court05 Jun 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 80

145 ITR 673 in the case of Searls (India) Ltd, the same High Court ruled that testing of samples in India and giving results and certificate to foreign company did represent technical services rendered outside India. In view of the forgoing discussion, I would hold that the assessee is not entitled for deduction u/s 80-O as the services made

ASSOCIATED POWER CO. LTD. vs. COMMISSIONER OF INCOME-TAX

In the result, the identical question referred to us in

- 0Supreme Court28 Nov 1995
For Respondent: COMMISSIONER OF INCOME-TAX
Section 257Section 57

section 10(1) of the Income-tax Act cannot obviously include the amounts returned by him by way of rebate to the consumers under statutory compulsion. It is as if he received only from the consumers the original amount minus the amount he returned to them. In substance there cannot be any difference between a businessman collecting from his constituents

M/S. COAL HANDLERS PVT. LTD. vs. COMMNR. OF CENTRAL EXCISE, KOLKATA

The appeals are allowed and

C.A. No.-007215-007215 - 2004Supreme Court05 May 2015
Section 65Section 65(25)Section 65(48)(j)Section 69

145) ELT 222 Civil Appeal No. 7215 of 2004 & Ors. Page 5 of 19 Page 6 JUDGMENT client and any incidental or auxiliary support service such as billing, collection or recovery of cheques, accounts and remittance, evaluation of prospective customer and public relation services, and includes services as a commission agent. The CESTAT, however, held that the activities undertaken

COMMISSIONER OF GST AND CENTRAL EXCISE vs. M/S CITIBANK N.A

C.A. No.-008228 - 2019Supreme Court09 Dec 2021

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

Section 35L(1)(b)Section 64(3)Section 65Section 65(10)Section 65(105)Section 65(12)Section 65(7)Section 83

Section 66 B accompanied by the definition of service under Section 65B (44) and the legislature further providing for the negative 80 list of services which stood excluded from the levy of service tax in Section 66 D, the question would only be whether there is any service and whether it is excluded under Section 66 D. The relevant part

M/S APEX LABORATORIES P. LTD. vs. THE DEPUTY COMMISSIONER OF INCOME TAX LARGE TAX PAYER UNIT II

The appeal is dismissed without order on costs

C.A. No.-001554-001554 - 2022Supreme Court22 Feb 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 142(1)Section 37(1)

145. Mr Rao submitted that since, by reason of the provisions of Article 105(2), the alleged bribe-takers had committed no offence, the alleged bribe-givers had also committed no offence. Article 105(2) does not provide that what is otherwise an offence is not an offence when it is committed by a Member of Parliament

M/S. AMCO BATTERIES LTD., BANGALORE vs. COMMNR. OF CENTRAL EXCISE, BANGALORE

In the result, Section 33-B of the Amended Act is held to be

C.A. No.-005941-005942 - 1999Supreme Court26 Feb 2003
For Respondent: Collector of Central Excise, Bangalore
Section 3

Section 123 of the Evidence Act in respect of what has been described for the sake of brevity to be the Blue Book summoned from the Government of Uttar Pradesh and certain documents summoned from the Superintendent of Police, Rae Bareli, Uttar Pradesh? The Court observed that "the right to know which is derived from the concept of freedom

M/S. ESCORTS LTD. vs. COMMNR. OF CENTRAL EXCISE, FARIDABAD

The appeal is allowed accordingly

C.A. No.-006561-006561 - 2004Supreme Court29 Apr 2015

transferred any transmission assemblies to any other person. However, they have been supplying the transmission assembly to their own units at Nagpur and Rudhrapur for manufacturing tractors. (b) It is submitted that this letter can at most lead to a conclusion that the transmission assembly made by M & M is marketable. 50. The show cause notice has placed reliance