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13 results for “transfer pricing”+ Section 145(3)clear

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Key Topics

Section 808Section 37(1)5Section 34Exemption4Section 653Section 473Section 1452Penalty2Addition to Income2

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 At this stage, we need to emphasise once again that the above system of commercial accounting can be superseded or modified by legislative enactment.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

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

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 - 2003Supreme Court24 Nov 2005
For Respondent: Commissioner of Income-tax, Mumbai
Section 80

3 of 10 assessee to value it as the closing stock of the First year. The Revenue challenged this order of the Tribunal in the High Court of Bombay by filing an Income-tax Appeal. The Division Bench of the High Court by its judgment dated 11.12.2002 allowed both the appeals and held that the method of valuation of closing

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

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

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

3 crores to Rs 250 crores per annum during the period 2002-2003 to 2006-2007. Even after 11-2-2007, taxes are being paid by VIH ranging from Rs 394 crores to Rs 962 crores per annum during the period 2007-2008 to 2010-2011 (these figures are apart from indirect taxes which also run in crores). Moreover

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

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

3 of 9 treated as income unless it has been received or there is a reasonable certainty that it will be realised." (Vide State Bank of Tranvacore v. CIT [supra]) The assessee’s method of accounting, therefore, transferring the doubtful debt to an interest suspense account and not treating it as profit until actually received, is in accordance with accounting

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

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

3. A question has been raised as to whether the benefit of Section 80-O would be available if the technical and professional services, though rendered outside India, are used by the foreign government or enterprise in India. “4. The matter has been considered by the Board. It is clarified that as long as the technical and professional services

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)

3. Section 37(1) of Income Tax Act provides for deduction of any revenue expenditure (other than those failing under sections 30 to 36) from the business Income if such expense is laid out/expended wholly or exclusively for the purpose of business or profession. However, the explanation appended to this sub-section denies claim of any such expense

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

3) STR 321 (Tri.-LB) :: 2006 (110) ECC 634 :: 2006 ECR 634 Tri Delhi Civil Appeal No. 7215 of 2004 & Ors. Page 8 of 19 Page 9 JUDGMENT and arrangements for transfer of goods to their destination, which process may also involve clearance at subsequent stages during forwarding operations. In the opinion of the larger Bench, the procurer of orders