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59 results for “transfer pricing”+ Section 55clear

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Key Topics

Section 26028Section 260A24Section 10A20Comparables/TP17Deduction13Section 10(20)10Addition to Income9Section 80P(2)(a)8Transfer Pricing

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

Transfer Pricing Adjustments results in multi- layer litigation at multiple Fora. After the lengthy process of the same, the matter reaches the Tribunal which also takes its own time to decide such appeals. In the course of this dispute resolution, much has already been lost in the form of time, man-hours and money, besides giving an adverse picture

M.Y.Maharshi vs. The Asst. Commissioner of Income-Tax

In the result, we do not find

ITTA/282/2013HC Telangana16 Jul 2013
Section 10ASection 143(1)Section 143(2)

Showing 1–20 of 59 · Page 1 of 3

8
Exemption7
Section 12A6
Section 8O6
Section 260
Section 92C

transfer pricing issues have to be determined on the basis of financial sun transactions of the previous financial year relevant to the assessment year involved as mandated under Rule 10B of the Rules. Alternatively, it is submitted that the order passed by the Tribunal has been passed without any reasons and suffers from the vice of non-application of mind

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

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

transfer of ownership has to be for a "price paid or promised or part-paid and part-promised." Price thus constitutes an essential ingredient of the transaction of sale. The words "price paid or promised or part-paid and part-promised" indicate that actual payment of the whole of the price at the time of the execution of the sale

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

55(2) of the Transfer of Property Act requires that seller must have the power to execute the sale deed and which power comes to the defendants/sellers having in this case obtained the necessary NOC from the concerned authority under the Delhi Land (Restrictions on Transfer) Act, 1972. Though it is not as if that in a suit for specific

The Commisioner of Income TAx-1 vs. Divya Shakti Granites Ltd.,

ITTA/178/2015HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 96

55 of the Transfer of Property Act, 1882 mounted on the shoulders of vendor to vouch a clear and marketable title, unless contrary is contracted. It has been held by the Privy Council in MOTILAL vs. NANHELAL5 that there is an implied covenant by the vendor to do all things necessary to effect a transfer; so when a vendor contracts

The Commissioner of Income Tax-II, vs. M/S Gulf Oil Corporation Pvt. Ltd.,

ITTA/195/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

transferred   to   somebody   else,   it   is   necessary  that   evidence   should   be   there   to   prove   that  change in hands. Thus it cannot be claimed by the  assessee that he/ she does not have evidence to  prove the factum of sale or purchases. Therefore,  producing   evidence   in   this   regard   was   not  physically impossible for the assessee and if the  same

Commissioner of Income Tax-II vs. M/s.Jayalakshmi Chits

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

transferred   to   somebody   else,   it   is   necessary  that   evidence   should   be   there   to   prove   that  change in hands. Thus it cannot be claimed by the  assessee that he/ she does not have evidence to  prove the factum of sale or purchases. Therefore,  producing   evidence   in   this   regard   was   not  physically impossible for the assessee and if the  same

The Commissioner of Income Tax - VI vs. M/s. Manikanta Iron AND Hardware

ITTA/196/2008HC Telangana02 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

transferred   to   somebody   else,   it   is   necessary  that   evidence   should   be   there   to   prove   that  change in hands. Thus it cannot be claimed by the  assessee that he/ she does not have evidence to  prove the factum of sale or purchases. Therefore,  producing   evidence   in   this   regard   was   not  physically impossible for the assessee and if the  same

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

price received by the respondent was at the rate of Rs.136 per share the full value of the consideration must be taken at the rate of Rs.136 per share. The view that we have expressed as to the interpretation of the main part of section 12B(2) is borne out by the fact that in the first proviso to section

Commissioner of Income Tax vs. Sri Chirla Rama Reddy, Contract

Appeal is dismissed with costs

ITTA/70/2007HC Telangana23 Mar 2016

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

price for sale of property sold by her husband which is western portion of Tataguni estate in favour of plaintiff-Company and she has not agreed to sell the plaint schedule property to the plaintiff at the rate of Rs.40,000/- per acre. 17. It is further claimed that Managing Director of plaintiff-Company K.T. Bhagath was with

COMMISSIONER OF INCOME TAX-III, HYD vs. M/S. SUJANA METALS LTD, HYD

ITTA/549/2011HC Telangana21 Apr 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260Section 28

price; and (ii) In any other case [not being a case falling under sub-clauses (i) to (iv) of sub-section (1) of section 49], shall be taken to be nil” ITA 549/2011 Page 11 of 16 9. This provision clearly provides determining the cost of any relation to a capital asset being the right to manufacture, produce or process

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

price, but instead of getting a deed of conveyance gets a SA/GPA/WILL as a mode of transfer, either at the instance of the vendor or at his own instance. Ill - effects of SA/GPA/WILL transactions: Page 41 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. 3. The earlier order

THE COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. M/S. PADMAVATHI MANSION (P) LTD., VIJAYAWADA

ITTA/700/2017HC Telangana21 Nov 2017

Bench: C.V.NAGARJUNA REDDY,T.AMARNATH GOUD

Section 10ASection 260Section 260A

Transfer Pricing Adjustments’ made by the concerned authorities below. We consider it appropriate to quote Date of Judgment 05-07-2018 I.T.A.No 700/2017. The Pr. Commissioner of Income-Tax, CIT (A) & Anr. Vs. M/s. Global E-Business Operations Pvt. Ltd., 7/15 from the order of Tribunal rejecting the Application seeking a review before Tribunal as hereunder:- “7.3 We have considered

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

price, and requesting them to place an order with the foreign headquarters were not auxiliary or preparatory in nature. The observations and findings of the High Court are eerily similar to the facts of this case: “Relying on these provisions, it is contended by the assessee that the liaison office was opened to act as a communication channel between

Shri Maneklal Agarwal vs. The Deputy Commissioner of Income Tax

The appeals are allowed and

ITTA/2/2005HC Telangana25 Feb 2015

Bench: A RAMALINGESWARA RAO,DILIP B. BHOSALE

transfer. After whole of the sale consideration is received by proposed vendors, the proposed vendees would be competent to sell these plots and the proposed vendors will have no objection to the same. (Emphasis supplied on altered portion) 18. For determining the issue raised by the learned Senior Counsel appearing for the appellants, the purport of clauses

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

55 and 56 IV th Phase, Adityapur, Jamshedpur through its Director-cum- Authorized Signatory Dilip Kumar Goyel ..... … Petitioner Versus 1. The State of Jharkhand 2. Secretary-cum-Commissioner, Commercial Taxes Department, Project Building, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur 4. Deputy Commissioner of Commercial Taxes (Adityapur Circle), Jamshedpur 5. Assistant Commissioner of Commercial Taxes

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

55 and 56 IV th Phase, Adityapur, Jamshedpur through its Director-cum- Authorized Signatory Dilip Kumar Goyel ..... … Petitioner Versus 1. The State of Jharkhand 2. Secretary-cum-Commissioner, Commercial Taxes Department, Project Building, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur Division, Jamshedpur 4. Deputy Commissioner of Commercial Taxes (Adityapur Circle), Jamshedpur 5. Assistant Commissioner of Commercial Taxes

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 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)

55 / 79 CRA-322-08gr between defendants no.1 and 2 in respect of the suit premises. Plaintiffs not only admitted execution of the said document but also admitted that atleast before 1972 the suit premises were occupied by defendant no.2 as licensee of defendant no.1. The Appellate Court also held that the suggestion given by the plaintiffs would establish

THE COMMISSIONER OF INCOME TAX-IV, HYDERABAD vs. M/S NAVA BHARAT VENTURES LTD., HYDERABAD

ITTA/251/2014HC Telangana18 Jun 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

For Respondent: C V NARA
Section 260Section 260ASection 80Section 8O

55,899 l- in resPect of assessment Year. Further; the As the deduction claimed bY the ass the Act, 1961 from Rs.44,92'O4'8 invoking the Provisions of Secti IA(10) of the Act, 1961 and also o which were set uP are onlY for C the APSEB has granted sanction o Consumption. Since the main ob plant