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105 results for “transfer pricing”+ Section 6(1)clear

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Key Topics

Section 26067Addition to Income34Section 8032Section 10A27Section 260A27Transfer Pricing20Deduction19Comparables/TP17Section 10(20)

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)

price paid or promised, or of money, a share 57 / 79 CRA-322-08gr of crops, service or any other thing of value to be rendered periodically or on specified occasions to the transferor by the transferee, who accepts the transfer on such terms. Relying upon this judgment as also Section 105 of T.P. Act he submitted that leave

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

ITTA/537/2015HC Telangana02 Nov 2015

RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Showing 1–20 of 105 · Page 1 of 6

10
Survey u/s 133A10
Section 80H9
Section 968
Bench:
Section 260

Transfer Pricing/ determination of the ‘Arm’s Length Price’; [II] The Scheme of procedure of assessment and appeals to the Tribunal and High Court/Supreme Court. [III] The scope of interference by High Court under Section 260-A of the Act in these type of cases. Findings of the Tribunal: 12. We find it appropriate to quote some portions

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

Commissioner of Income Tax, Guntur. vs. Agricultural Market Committee, Kangiri.

ITTA/318/2008HC Telangana01 Mar 2011

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

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

Commissioner of Income Tax, vs. Agricultural Market Committee,

ITTA/251/2008HC Telangana01 Mar 2011

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

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

The Commissioner of Income Tax, vs. M/s. Laila Impex,

Accordingly answered against the Revenue. The appeals fail and are dismissed, without

ITTA/473/2012HC Telangana09 Jul 2013
Section 143(3)Section 144CSection 260ASection 9(1)(vi)

6 9. (1) The following incomes shall be deemed to accrue or arise in India (vi) income by way of royalty payable by— (a) the Government ; or (b) a person who is a resident, except where the royalty is payable in respect of any right, property or information used or services utilised for the purposes of a business or profession

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

1) or (3)a of Section-5 of the Central Sales Tax Act, 1956 and ii) Inter-state sales of taxable goods falling within the scope of Section 3 of the CST Act, but shall not include: i) Purchase price of goods taxable under Section 10 of the CST Act; ii) Transaction falling under Section 5(2), Section 6

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

1) or (3)a of Section-5 of the Central Sales Tax Act, 1956 and ii) Inter-state sales of taxable goods falling within the scope of Section 3 of the CST Act, but shall not include: i) Purchase price of goods taxable under Section 10 of the CST Act; ii) Transaction falling under Section 5(2), Section 6

M/S.R.S.RANGADAS vs. THE ASST.COMMISSIONER OF INCOME TAX

Appeals are disposed of, with no order as to costs

ITTA/406/2005HC Telangana19 Oct 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 2(47)Section 271(1)(c)Section 45(1)Section 48Section 54F

6. The Assessing Officer vide assessment order dated 27th March, 2001 for the AY 1998-99 held that one lakh equity shares of NIIT were not sold and transferred to M/s GIPL vide agreement dated 14th August, 1997. The transfer was on 30th September, 1998 i.e., in the subsequent AY 1999-2000. After referring to the term „transfer‟ in relation

THE PRL COMMISSIONER OF INCOME TAX-II, VISAKHAPATNAM vs. L SURYAKANTHAM, VISAKHAPATNAM

In the result, the appeal fails and is hereby dismissed

ITTA/285/2017HC Telangana08 Oct 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 143(2)Section 14ASection 260Section 80JSection 92C

Transfer Pricing Officer has been affirmed by the Dispute Resolution 6 Panel. However, the Tribunal has partly allowed the appeal preferred by the assessee merely on the ground that the assessee cannot be said to be an associated enterprise and therefore, the requirements of Section 92A(1

COMMISSIONER OF INCOME TAX-II, HYDERABAD vs. M/s. The A.P.Vardhaman(Mahila)Cooperative Urban

In the result, for the above reasons, these appeals fail and

ITTA/715/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

1)(n) of the BR Act, the doing of all such other things as are incidental or conducive to the promotion or advancement of the business of the company. Thus reading of Sections 5(b), (c) and Section 6 of the BR Act along with Section 80P(2)(a) of the Act, it becomes clear that the income received

Commissioner of Income Tax -II vs. The Agrasen Coop. Urban Bank Ltd.,

In the result, for the above reasons, these appeals fail and

ITTA/711/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

1)(n) of the BR Act, the doing of all such other things as are incidental or conducive to the promotion or advancement of the business of the company. Thus reading of Sections 5(b), (c) and Section 6 of the BR Act along with Section 80P(2)(a) of the Act, it becomes clear that the income received

Commissioner of Income Tax-II, vs. M/S The A.P.Mahesh Coop. Urban Bank Ltd,

In the result, for the above reasons, these appeals fail and

ITTA/718/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

1)(n) of the BR Act, the doing of all such other things as are incidental or conducive to the promotion or advancement of the business of the company. Thus reading of Sections 5(b), (c) and Section 6 of the BR Act along with Section 80P(2)(a) of the Act, it becomes clear that the income received

The Commissioner of Income Tax-II vs. The Andhra Bank Employees Co.Operative Bank Limited

In the result, for the above reasons, these appeals fail and

ITTA/243/2007HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

1)(n) of the BR Act, the doing of all such other things as are incidental or conducive to the promotion or advancement of the business of the company. Thus reading of Sections 5(b), (c) and Section 6 of the BR Act along with Section 80P(2)(a) of the Act, it becomes clear that the income received

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

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

6) The terms 'effectively connected' and 'attributable to' are to be construed differently even if the offshore services and the permanent establishment were connected. ITA 666/2014 & Ors. Page 34 of 57 (7) Section 9(1)(vii)(c) of the Act in this case would have no application as there is nothing to show that the income derived

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

price per acre (4 bighas 16 biswas or 4,840 sq yds) being 1,25,25,000/-. Plaintiff under the two Agreements to Sell dated 25.9.2006 paid a sum of Rs.40 lacs. A further amount of Rs.13 lacs was paid by the plaintiff to the defendants on 5.10.2006 which was acknowledged by means of a Receipt dated 10.10.2006. In terms

The Commissioner of Income Tax-II, vs. M/s Padmapriya Real Estates AND Financiers

In the result, the appeal is allowed and the impugned judgment passed by

ITTA/478/2006HC Telangana10 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 13(1)(e)Section 13(2)Section 313

transfer at Jagdalpur, he handed over the further investigation to Sahid Ali / P. K. Shukla under the instruction of Superintendent of Police. In cross-examination he admitted that he has not 13 come across about any circular that 60% of the total amount is to be considered as expenditure and 40% is to be considered as savings. He further admitted

Commissioner of Income-Tax, vs. Rangaraya Medical College Old Students Association

ITTA/269/2005HC Telangana14 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

For Appellant: SRI CHALLA GUNARANJAN
Section 1Section 151

Section 16 of the Reforms Act, was granted. The order passed by the APERC was upheld by a Bench of this Court by an order dated 08.O6.2O01 in C.M.A.No.L97I of 2OOO and other connected matters- 10. Against the aforesaid order passed by a Bench of tltis Court, a Special Leave Peti(ion was preferred. 11. The Honble Supreme

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)Section 260Section 92C

1) on 10.09.2007. Subsequently, the case of the assessee was selected for scrutiny and notice under Section 143(2) of the Act was issued on 05.10.2007. During the relevant financial year, it was observed that the assessee had international transactions exceeding Rs.15 Crores. Therefore, with prior approval of the Commissioner of Income Tax 5 (Appeals), Bangalore-I, Bangalore, a reference

The Commissioner of Income Tax (Central) vs. Akula Nageswara Rao

In the result, the orders passed by the Assessing

ITTA/422/2017HC Telangana10 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

Section 39(1)Section 5Section 65(1)Section 9(2)

price as well as the terms and conditions. The aforesaid quotation states that Dell product would be exported from Malaysia. Thus, the petitioner seeks customer's upfront contractual approval of manufacture and supply of required product from Malaysia. On receipt of the quotation, customer accepts either by signing the same or by raising a purchase order or by making