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10 results for “transfer pricing”+ Section 158clear

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Key Topics

Section 144C6Section 37(1)5Section 473Addition to Income3Section 1042Section 652Section 1532Section 153(1)2Penalty2Exemption

ASSISTANT COMMISSIONER OF INCOME TAX vs. SHELF DRILLING RON TAPPMEYER LIMITED

The appeals are allowed

C.A. No.-010586-010589 - 2025Supreme Court08 Aug 2025

Bench: HON'BLE MRS. JUSTICE B.V. NAGARATHNA

Section 144CSection 153Section 153(1)Section 44B

Transfer Pricing Officer, then under Section 92CA of the Act as there is an extension of the period of twenty-one months contemplated under Section 153(1) of the Act by a further period of twelve months, the total time period is increased to thirty-three months for passing an assessment order from the end of the relevant year. That

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

Appeals stand disposed of in the aforesaid terms

2
C.A. No.-000152-000152 - 2026
Supreme Court
09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

158 ITR 102 (SC) 10 Commissioner of Income-Tax15 and Commissioner of Income-Tax v. Excel Industries Ltd. and another16. Even if the fair market value of the shares allotted in the amalgamated company on the date of allotment exceeds the book value of the shares in the amalgamating company, such appreciation is purely notional. Real income would arise only

M/S D. N. SINGH THROUGH PARTNER DUDHESHWAR NATH SINGH vs. COMMISSIONER OF INCOME TAX

C.A. No.-003738-003739 - 2023Supreme Court16 May 2023

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

Section 260A

158 of the Indian Contract Act speaks of bailment of the goods for being carried on behalf of that bailor, but it is also to be noticed that the bailment spoken of in that section is gratuitous as it is specifically provided “bailment” as set out in Section 148 of the Indian Contract Act may be said to be wide

M/S. D.J. MALPANI vs. COMMISSIONER OF CENTRAL EXCISE, NASHIK

C.A. No.-005282-005282 - 2005Supreme Court09 Apr 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 11ASection 173QSection 4

Section 11AA should not be levied. After hearing the appellant, the Deputy Commissioner held vide order dated 26.02.2002 that Dharmada cannot be considered as trading receipts and was not part of the assessable value. Therefore, no duty was payable on the component of Dharmada. 5. Thereafter, in an appeal filed by Revenue, the Commissioner (Appeals), however, held that the Dharmada

DELHI FARMING & CONSTRUCTION(P) LTD. vs. COMMNR. OF INCOME TAX, DELHI

In the result, we set aside the judgment of the High Court and uphold the

C.A. No.-007525-007527 - 2001Supreme Court26 Mar 2003
For Respondent: COMMISSIONER OF INCOME TAX, DELHI
Section 104

158 ITR 621 and Commissioner of Income Tax v. South India Corporation Ltd., (1990) 183 ITR 361 (Ker). The High Court was persuaded to hold that if such losses as are referred to in clause (d) are deductible from the gross total income, there is no scope for entertaining a doubt that capital gains form part of the gross total

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

Section 12AA(1) of the IT Act, on 18.05.1979 and is engaged in the activity of promotion of the export of all kind of ready-made garments, knitwear, and garments made of leather, jute and hemp. It does not per se engage in any activity for profit, and its mandate is to ensure that Indian apparel manufacturers, are given forums

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

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

158 ITR 102 at p.120]. It is as follows: "Where interest has not been paid, it is sometimes left out of account altogether. This prevents the possibility of irrecoverable interest being credited to revenue, and distributed as profit. On the other hand, this treatment does not record the actual state of the loan account, and in the case of banks

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)

158. 17 See regulation 8 of the 2002 Regulations. 18 (2012) 344 ITR 476 (P&H HC). 7 of payments as business expenditure, notwithstanding that such payments are illegal or opposed to public policy or have pernicious consequences to the society as a whole.” *** “If demanding of such commission was bad, paying it was equally bad. Both were privies