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19 results for “transfer pricing”+ Section 36(1)(vii)clear

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Key Topics

Section 260A8Addition to Income5Section 44Section 964Section 1514Section 214Section 2602Section 2(31)2

The Commissioner Of Income Tax (Central) vs. Madhu Enterprises

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

VII, Adityapur Industrial Area, Jamshedpur through its Managing Director- cum-Authorized Signatory Atul Taunk ..... … Petitioner Versus 1. The State of Jharkhand through the Secretary-cum-Commissioner, Commercial Taxes Department, Project Building, Dhurwa, Ranchi 2. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur 3. Deputy Commissioner of Commercial Taxes (Adityapur Circle), Jamshedpur .…. … Respondents With W.P.(T) No.3950

S.l. Shiva Raj vs. Commissioner of Income Tax,

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

VII, Adityapur Industrial Area, Jamshedpur through its Managing Director- cum-Authorized Signatory Atul Taunk ..... … Petitioner Versus 1. The State of Jharkhand through the Secretary-cum-Commissioner, Commercial Taxes Department, Project Building, Dhurwa, Ranchi 2. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur 3. Deputy Commissioner of Commercial Taxes (Adityapur Circle), Jamshedpur .…. … Respondents With W.P.(T) No.3950

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

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

36. The controversy whether the Assessee has a PE in India is interlinked to the finding that Nortel India had discharged some of the obligations of the Assessee under the Equipment Contract. Whilst, the Income Tax Authorities have held that the contracts entered into with Reliance – the Equipment Contact, Software Contract and Services Contract – are essentially a part

The Commissioner of Income Tax-V vs. The Armed Forces Officers Co.Op Housing Society Ltd

ITTA/78/2007HC Telangana27 Aug 2011

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

vii) The empty (as alleged by plaintiff) envelope sent by the defendant no.2 to the plaintiff as Ex.PW-1/8/Ex.P-11. CS(OS) No. 78/2007 Page 6 of 43 (viii) Envelope in which as per the plaintiff new year greetings were received as Ex.PW1/9/Ex.P-10 with the new year greetings paper found therein as Ex.PW-1/10. (ix) Legal Notice dated

The Commissioner of Income Tax-IV vs. M/s Pokarna Limited

The appeals are dismissed

ITTA/273/2012HC Telangana18 Feb 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260A

36 thereto of which the assessee is the owner, other than such portions of such property as he may occupy for the purposes of any business or profession carried on by him the profits of which are chargeable to income-tax, shall be chargeable to income-tax under the had ‘Income from house property’.” The section itself indicates that merely

The Pr. Commissioner of Income Tax-2 vs. M/s. GJ Trading Pvt Ltd

ITTA/246/2022HC Telangana05 Sept 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

36 + ITA 263/2022 THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1 NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kr., Mr. Rishabh Nangia, JSCs, Mr. Nikhil Jain and Ms. Srishti Sharma, Advs. versus M/S EXPEDITORS INTERNATIONAL OF WASHINGTON INC .....Respondent Through: Mr. Deepak Chopra, Mr. Rohan Khare and Mr. Priyam Bhatnagar, Advs. 37 + ITA 220/2023 THE COMMISSIONER

The Commissioner of Income Tax IV vs. New Bombay Goods Transport

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

36. In order to make the sale, as one in the course of inter-State trade or commerce, there must be an obligation to transport the goods outside the State. [Shankerjee Raut Gopalji Raut43; Bhag Singh Milkha Singh4; Ben Gorm Nilgiri Plantations Co. Coonoor (Nilgiris)41]. A sale, by definition, being transfer of property became taxable under Section

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

36. W.P.(C) No.17240/2020 is filed by a partnership firm “Poomala Granites”, challenging Exhibit-P21 order of the Tahsildar, Thrissur, denying permission to conduct quarry in the assigned lands. Petitioner therein has contended that even though they have produced Exhibit-P11 mining sketch, WP(C). 11249/2010 & other contd cases. -:70:- it has not been countersigned by the Tahsildar, and therefore

The Commissioner of Income TAx-IV, vs. M/s. Mahaveer Enterprises (India) Limited

The Appeal is dismissed

ITTA/94/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 21

36 of 76 C/LPA/94/2008 JUDGMENT DATED: 06/07/2021 RAVJIBHAI PRABHUDAS PATEL SINCE DECD. THR'HEIRS V/s ADDITIONAL COLLECTOR AND COMPETENT AUTHORITY U.L.C. Division Bench of this Court has clearly held that it is the nature and scope of holding that is decisive on this point if individuals, with specified shares, though acquired under or through a single source or transaction

The Commissioner of Income Tax IV vs. M/s. Nava Bharat Ferro Alloys Ltd.,

ITTA/392/2013HC Telangana05 Sept 2013
Section 14Section 14(1)(e)

36; Mussauddin Ahmed Vs. State of Assam (2009) 14 SCC 541; Pradip Buragohain Vs. Pranati Phukan (2010) 11 SCC 108; Freddy Fernandes Vs. P.L. Mehra 1973 RCR 53; State of W.B. Vs. MIR Mohammadomar & Ors. (2000) 8 SCC 382; Grand Vasant Residents WEL. ASS. Vs. DDA 2014 (4) AD (delhi) 193; State of U.P. Vs. Nahar Singh (Dead

Commissioner of Income Tax-1 vs. Agricultural Market Committee

ITTA/186/2011HC Telangana21 Apr 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

Section 151Section 96

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing

Commissioner of Income Tax vs. Agrilcultural Market Committee

ITTA/148/2011HC Telangana20 Apr 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

Section 151Section 96

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing

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

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

1 and 2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

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

1. STATE OF KARNTAKA REP BY ITS SECRETARY URBAN DEVELOPMENT DEPARTMENT M S BUILDING, DR AMBEDKAR VEEDHI BANGALORE-560001 2. BANGALORE DEVELOPMENT AUTHORITY REP BY ITS COMMISSIONER KUMARA PARK WEST BANGALORE-560020 3. SPECIAL LAND ACQUISITION OFFICER BANGALORE DEVELOPMENT AUTHORITY KUMARA PARK WEST BANGALORE-560020 …RESPONDENTS (BY SRI. G.V. SHASHIKUMAR, AGA FOR R1; SRI. M.N. RAMANJANEYA GOWDA, ADVOCATE

The Commissioner of Income Tax vs. M.Venkata Krishna Mohan

ITTA/325/2005HC Telangana07 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 143(3) of the Act and the income of the appellant was determined at Rs.84,95,035/-. The assessing Officer (hereinafter „AO‟) came to the conclusion that since the payment of Rs.1 Crore was absent in the earlier license agreement and it was for use of the brand, the expenditure of Rs.1 Crore cannot be related to the business

Principal Commissioner of Income Tax - 5 vs. M/s Vijay Textiles Limited

The appeal is dismissed

ITTA/541/2015HC Telangana16 Feb 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 167BSection 2(31)Section 2(47)Section 260Section 3Section 4Section 67A

VII. parties shall, after the First Party complies with their obligations, sign a formal agreement and submit for the approval of Income Tax Authorities.” 20. What strikes us from the above MOU is that assessee was not at all the owner of the property on the said date. Shri. Gopalakrishna Gowda had agreed to purchase the subject property through

The Commissioner of Income Tax (Central) vs. M/s Hyderabad House Pvt Ltd.,

ITTA/250/2013HC Telangana11 Jul 2013

36 of 70 who were sitting in the balcony class (where rate of admission was higher) as those belonging to a strata of society where the monthly income could not be less than ₹15,000/-. Adopting the multiplier of 15 in all such cases where the deceased persons were more than 20 years, after deducting 1/3rd for personal expenses, this

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

ITTA/121/2013HC Telangana26 Jul 2013

1-2-oswp-1494-2023-J+.docx a company incorporated under the Companies Act, 1956 having its corporate office at "BKT House", C/15, Trade World, Kamala Mills Compound, Senapati Bapat Marg, Lower Parel, Mumbai 400 013. …Petitioner ~ versus ~ 1. The State of Maharashtra, through the Department of Registration and Stamps, Ministry of Revenue, Government of Maharashtra, Mantralaya, Mumbai