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12 results for “transfer pricing”+ Section 147clear

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Key Topics

Section 260A4Section 2604Addition to Income4Section 13(1)(a)3Section 1083Section 1472Section 13(1)(b)2Double Taxation/DTAA2

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

ITTA/537/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

147 etc. are final and are binding on this Court. While dealing with these appeals under Section 260-A of the Act, we cannot disturb those findings of fact under Section 260-A of the Act, unless such findings are ex-facie perverse and unsustainable and exhibit a total non- application of mind by the Tribunal to the relevant facts

M/S VAIBHAV vs. JOINT COMM. OF INCOME TAX RANGE 3 HYD

Appeal is allowed and the judgments and decrees passed by the

ITTA/58/2002HC Telangana14 Sept 2022

Bench: The Learned Trial Court) Was Allowed & The Judgment & Decree Dated 12.12.2000, Passed By Learned Senior Sub Judge, Kullu Was Set-Aside. (Parties Shall Hereinafter Be Referred To In

Mr. Bimal Gupta, Sr. Advocate with
For Appellant:

price, and he will have a charge on the property for the unpaid purchase money. This is a non-possessory charge in terms of Section 55(4)(b) of the Act. 7. The factual position needs a reference for the application of the legal position, Muralidhar Mohanty (D.W. 4) is the husband of defendant No. 1. From his evidence

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

ITTA/621/2017HC Telangana23 Aug 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 260A

transferred outside India and the payments were also received outside India. It was pointed out that several activities relating to marketing and sales took place in India. Expatriates from GEII along with employees of GEIIPL constituting the Indian team were mostly involved and participated in the negotiation of prices. These price negotiations took place in India. The Indian customers discussed

The Commissioner of Income -Tax - III, vs. Shri Taher Ali

ITTA/322/2008HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 108Section 13(1)(a)Section 13(1)(b)Section 13(1)(e)

147. He also relied upon Section 21 of the Indian Evidence Act, 1872. 67. In paragraph 66, the Appellate Court observed that payment of compensation by defendant no.2 to defendant no.1 will have to be inferred. He submitted that the said finding, to say the least, is perverse. In short, he submitted that

Principal Commissioner of Income Tax-2 vs. M/s.Viskha Container Terminal Private Limited

ITTA/439/2018HC Telangana08 Oct 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 143(2)Section 260Section 268

Pricing Officer (TPO) vide letter dated 30.11.2009 and during the course of proceeding before the TPO, assessee vide its letter dated 09.06.2010 categorically stated that its registered office was at Hyderabad and it stood merged with Wipro Ltd., pursuant to the scheme of amalgamation approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and scheme of amalgamation

Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

ITTA/667/2014HC Telangana29 Jan 2015
Section 143(3)Section 147Section 260A

147 read with Section 143(3) of the Act in respect of the AYs 2003-04 and 2004-05 as well as an assessment order dated 31st December, 2007 passed by the AO in respect of assessment year 2005-06. 2. ITA Nos. 666/2014, 667/2014 and 673/2014 impugn a common order dated 13th June, 2014 passed by the ITAT

Sarwar Ahuja, vs. Income Tax Officer, Ward 6(1),

Accordingly dismissed. Pending applications are also dismissed

ITTA/173/2025HC Telangana28 Oct 2025

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

Section 144C(13)Section 147Section 260ASection 9(1)(vii)

147 read with Section 144C(13) of the Act. 3. The Assessee is a company, which is tax resident of the United States of America [USA]. The Assessee has also furnished a Tax Residency Certificate [TRC] from the concerned authorities of the said country. Digitally Signed By:TARUN RANA Signing Date:01.06.2025 13:30:53 Signature Not Verified ITA 173/2025

The Commissioner of Income Tax -III vs. Sri T.C. Reddy

The appeal stands dismissed

ITTA/577/2011HC Telangana28 Feb 2012

price paid found to be reasonable, taking an adverse view on the genuineness of M/s Mrigiya Electronics Inds. Pvt. Ltd. On the basis of some enquiry against it in some other case that too for different assessment year will not justified. The AO in Show Cause Notice informed the appellant that Sri Pramod Kumar Sharma, Director M/s Mrigya

PR COMMISSIONER OF INCOME TAX-2, HYDERABAD vs. M/S GOLDEN STAR FACILITIES AND SERVICES PVT LTD., HYD

ITTA/335/2017HC Telangana26 Sept 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 13 which provides for Rule making power of the Central Government in respect of minerals. Section 13 subsection (1) WP(C). 11249/2010 & other contd cases. -:88:- and Section 13 Sub-section (2) in so far as relevant in the present case are as follows: “13. Power of Central Government to make Rules in respect of minerals.-- (1) The Central

M/s. Canara Securities Ltd vs. Dy. Commissioner of Income Tax

ITTA/3/2020HC Telangana25 Aug 2020

Bench: M.S.RAMACHANDRA RAO,T.AMARNATH GOUD

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

The Pr. Commissioner of Income tax (Central), vs. Sri Vaishnavi Educational Society,

ITTA/622/2015HC Telangana01 Jun 2016

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.51929/2014 C/W W.P.Nos.42063/2012, 30494/2013, 42671/2013, 638/2014, 797/2014, 1089/2014, 3211/2014, 3389/2014, 6180/2014, 10356/2014, 12014/2014, 12015/2014, 13043/2014, 13045/2014, 13206/2014, 13207/2014, 13398/2014, 13774/2014, 14149/2014, 14161/2014, 14494/2014, 14502/2014, 14521/2014, 14689/2014, 16646/2014, 17051/2014, 17594/2014, 19729/2014, 21158/2014, 23897/2014, 28861/2014, 30731/2014, 31723/2014, 33774/2014, 33777/2014, 34084/2014, 34259/2014, 34272/2014, 34391/2014, 35204/2014, 35243/2014, 35247/2014, 35305/2014, 35609/2014, 36164/2014, 36166/2014, 36489/2014, 36525/2014, 36971/2014, 37446/2014, 38055/2014, 38463/2014, 38471/2014, 38472/2014, 38661/2014, 38753/2014, 39383/2014, 39633/2014, 39832/2014, 40204/2014, 40379/2014, 41394/2014, 41422/2014, 41427/2014, 41428/2014, 41858/2014, 43815/2014, 43963/2014, 44306/2014, 44527/2014, 44742/2014, 44835/2014, 45486/2014, 46766/2014, 47103/2014, 47105/2014, 47106/2014, 47107/2014, 47608/2014, 47731/2014, 47821/2014, 47860/2014, 47913/2014, 48577/2014, 48880/2014, 49567/2014, 50260/2014, 50533/2014, 51294/2014, 51930/2014, 51931/2014, 51932/2014, 52760/2014, 53854/2014, 54059/2014, 54083/2014, 54236/2014

SECTION 19(1) OF THE BDA ACT I.E., ANNEX-P, IN SO FAR AS IT RELATES TO THE PROPERTIES OF THE PETITIONER IN SY.NO.30/6 & 30/7, K. NARAYANAPURA VILLAGE, K.R. PURAM HOBLI, BANGALORE SOUTH TALUK, MEASURING 22 GUNTAS AND 26 GUNTAS RESPECTIVELY. IN W.P.NO.55081/2014: BETWEEN: MR N. R. VENKATESHMURTHY S/O SRI. RAMAKRISHNAPPA, AGED ABOUT 45 YEARS, R/AT HOUSE NO.5

The commissioner of Income Tax IV vs. M/s Lanco Kondapalli Power (P) Ltd

ITTA/121/2013HC Telangana26 Jul 2013

147 of 198 22nd March 2024 Saurer Textile Solutions Pvt Ltd v The State of Maharashtra & Ors & Connected Writ Petitions 1-2-oswp-1494-2023-J+.docx respondent no. 3 in WP/412/2023, WP/385/2023, WP/422/2023, WP/17566/2022, WP/18022/2022, WP/560/2023, WPL/22235/2022, WPL/23214/2022, WPL/23846/2022, WP/4587/2022, WP/4490/2022, WP/4824/2022 & WPL/35848/2022. for respondent no.3 Mr Advait Sethna, with Ruju Thakker. for respondent in WP/152/2023 & WP/153/2023-Customs, for respondent