BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

143 results for “transfer pricing”+ Business Incomeclear

Sorted by relevance

Mumbai4,956Delhi4,928Bangalore2,074Chennai1,050Kolkata952Ahmedabad694Hyderabad688Pune642Jaipur438Karnataka343Indore252Chandigarh246Cochin224Surat145Visakhapatnam143Rajkot115Telangana77Cuttack73Calcutta69SC64Nagpur63Raipur62Lucknow61Amritsar45Guwahati37Jodhpur31Agra31Dehradun21Ranchi14Varanasi13Panaji12Rajasthan11Jabalpur11Allahabad11Patna10Kerala9Orissa5A.K. SIKRI ROHINTON FALI NARIMAN3Punjab & Haryana3A.K. SIKRI N.V. RAMANA1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1D.K. JAIN JAGDISH SINGH KHEHAR1MADAN B. LOKUR S.A. BOBDE1

Key Topics

Section 143(3)77Addition to Income46Section 92C39Section 153A34Section 14825Section 80I22Transfer Pricing22Disallowance22Section 132

LEWEK ALTAIR SHIPPING PRIVATE LIMITED,KAKINADA vs. DCIT, CIRCLE-1, KAKINADA

In the result, appeal filed by the assessee is allowed

ITA 41/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam14 Jul 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri Jitendra Singh, ARFor Respondent: Sri ON Hari Prasada Rao
Section 115VSection 139(5)Section 143(2)Section 143(3)Section 144CSection 92CSection 92E

business or profession". As under the tonnage tax scheme, the actual receipts/revenues earned and expenses incurred are not taken into consideration for the purpose of determining the tonnage income of the company, therefore, in our considered view the applicability of the transfer pricing

Showing 1–20 of 143 · Page 1 of 8

...
21
Section 143(2)19
Section 10A15
Deduction15

THE ITO,, VIJAYAWADA vs. PEDARLA SRINIVASA MURTHY,, VIJAYAWADA

In the result, the appeals filed by the revenue for the A

ITA 124/VIZ/2016[2008-09]Status: DisposedITAT Visakhapatnam09 May 2018AY 2008-09

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri Y. Sesha Srinivas, DR
Section 10(38)Section 143(3)

price whichever is lower, the gain arising out of sale of shares could be treated as business income. Appellant had not valued the shares as stock but valued the same as investment. Thus, what was a capital asset will remain a capital asset unless the person holding the asset himself changes the nature by a specific action like conversion

THE ITO,, VIJAYAWADA vs. PEDARLA SRINIVASA MURTHY,, VIJAYAWADA

In the result, the appeals filed by the revenue for the A

ITA 123/VIZ/2016[2007-08]Status: DisposedITAT Visakhapatnam09 May 2018AY 2007-08

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri Y. Sesha Srinivas, DR
Section 10(38)Section 143(3)

price whichever is lower, the gain arising out of sale of shares could be treated as business income. Appellant had not valued the shares as stock but valued the same as investment. Thus, what was a capital asset will remain a capital asset unless the person holding the asset himself changes the nature by a specific action like conversion

THE DY. CIT,, VISAKHAPATNAM vs. M/S. SNF (INDIA) LIMITED,, VISAKHAPATNAM

In the result, appeals filed by the Revenue and the Cross objections filed by the assessee are dismissed

ITA 280/VIZ/2017[2008-2009]Status: DisposedITAT Visakhapatnam04 Oct 2019AY 2008-2009

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri Ajit Kumar Jain – ARFor Respondent: Smt. Suman Malik – Sr.DR

Transfer Pricing Officer (TPO) for allowing royalty payment. Ground Nos.4 to 7 are related to determination of arm’s length price (ALP) in respect of payment of royalty to the Associated Enterprises (AEs). 4. Brief facts of the case are that the assessee–SNF India Private Ltd., is a 100% subsidiary of SPCM SA, France has set up its manufacturing

THE DY. CIT,, VISAKHAPATNAM vs. M/S. SNF (INDIA) LIMITED,, VISAKHAPATNAM

In the result, appeals filed by the Revenue and the Cross objections filed by the assessee are dismissed

ITA 279/VIZ/2017[2007-2008]Status: DisposedITAT Visakhapatnam04 Oct 2019AY 2007-2008

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri Ajit Kumar Jain – ARFor Respondent: Smt. Suman Malik – Sr.DR

Transfer Pricing Officer (TPO) for allowing royalty payment. Ground Nos.4 to 7 are related to determination of arm’s length price (ALP) in respect of payment of royalty to the Associated Enterprises (AEs). 4. Brief facts of the case are that the assessee–SNF India Private Ltd., is a 100% subsidiary of SPCM SA, France has set up its manufacturing

OCEAN INDIA PVT. LTD.,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, appeal filed by the assessee is allowed

ITA 150/VIZ/2016[2011-12]Status: DisposedITAT Visakhapatnam23 Nov 2020AY 2011-12

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blei.T. (T.P.) A. No. 150/Viz/2016 (Asst. Year : 2011-12) M/S. Teejay India Pvt. Ltd. Vs. The Acit, Circle-5(1), (Formerly Known As Ocean Visakhapatnam. India Pvt. Ltd.), Plot No. 15, Brandix India Apparel City Pvt. Ltd. Sez, Pudimadaka Road, Atchutapuram, Visakhapatnam. Pan No. Aaaco 9452 H (Appellant) (Respondent)

For Appellant: Shri Ajith Tolani/For Respondent: Shri D.K.Sonowal, CIT(DR)
Section 143(3)Section 92C(3)

Income-tax Rules, 1962, ('the Rules'); 3.2. Rejecting the Comparable Uncontrolled Price method ('CUP') as the most appropriate method, as applied by the Appellant in its transfer pricing documentation for both the purchase and sales transactions; 3.3. Disregarding the conditions prescribed under section 92C(3) of the Act for determining the arm's length price for international transaction in relation

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 169/VIZ/2014[2005-06]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2005-06

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

MYNENI VENKATA RAO,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, appeals of the assessee for the A

ITA 130/VIZ/2015[2008-09]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2008-09

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 174/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2010-11

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 173/VIZ/2014[2009-10]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2009-10

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 171/VIZ/2014[2007-08]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2007-08

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 168/VIZ/2014[2004-05]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2004-05

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 170/VIZ/2014[2006-07]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2006-07

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

ARUNACHALAM MANICKAVEL,PROP: BHARATHI SOAP WORKS, 1ST LANE,,GUNTUR vs. THE ACIT, CIRCLE - 2(1),, GUNTUR

In the result, appeals of the assessee for the A

ITA 172/VIZ/2014[2008-09]Status: DisposedITAT Visakhapatnam20 Mar 2019AY 2008-09

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singh

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri D.K.Sonowal, CIT DR
Section 132Section 143(3)Section 153A

price of raw material consumed is net of CENVAT, which is in the region of 12% to 15% . Thus, , gross profit reflected in its trading account is arrived after taking into account the CENVAT credit. For unaccounted purchases/trading purchases, there would be no CENVAT credit and hence gross profit percentage would be reduced by the amount of CENVAT credit

SMT GOGINENI SARADA VANI,,VIJAYAWADA vs. THE ITO,, VIJAYAWADA

In the result, appeal filed by the Revenue is dismissed and that of assessee is allowed

ITA 152/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam31 Jul 2018AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleito, Ward-2(2), Vs. Smt. Gogineni Sarada Vijayawada. Vani, 40-7-13, J.C. Plaza, Jammichettu Street, Moghalrajpuram, Vijayawada. Pan No. Acfpg 5834 R (Appellant) (Respondent) Smt. Gogineni Sarada Vani, Vs. Ito, Ward-2(2), 40-7-13, J.C. Plaza, Vijayawada. Jammichettu Street, Moghalrajpuram, Vijayawada. Pan No. Acfpg 5834 R (Appellant) (Respondent)

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: Shri M.N. Murthy Naik, Sr.DR
Section 143(3)Section 45(2)Section 54F

price and easy saleability. Even then, the assessee had kept the plots for more than 5 years and no prudent business person will keep asset idle without optimising the turnover. Merely because the plots were sold for profit, it cannot be held that income arising from the sale of plots was taxable as profit arising from the adventure

THE ITO,, VIJAYAWADA vs. SMT GOGINENI SARADA VANI,, VIJAYAWADA

In the result, appeal filed by the Revenue is dismissed and that of assessee is allowed

ITA 122/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam31 Jul 2018AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleito, Ward-2(2), Vs. Smt. Gogineni Sarada Vijayawada. Vani, 40-7-13, J.C. Plaza, Jammichettu Street, Moghalrajpuram, Vijayawada. Pan No. Acfpg 5834 R (Appellant) (Respondent) Smt. Gogineni Sarada Vani, Vs. Ito, Ward-2(2), 40-7-13, J.C. Plaza, Vijayawada. Jammichettu Street, Moghalrajpuram, Vijayawada. Pan No. Acfpg 5834 R (Appellant) (Respondent)

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: Shri M.N. Murthy Naik, Sr.DR
Section 143(3)Section 45(2)Section 54F

price and easy saleability. Even then, the assessee had kept the plots for more than 5 years and no prudent business person will keep asset idle without optimising the turnover. Merely because the plots were sold for profit, it cannot be held that income arising from the sale of plots was taxable as profit arising from the adventure

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

In the result, appeal filed by the assessee is partly allowed

ITA 152/VIZ/2021[2016-17]Status: DisposedITAT Visakhapatnam23 Jan 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri Darpan Kirpalani CAFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 10ASection 142(1)Section 143(2)Section 143(3)Section 36(1)(va)Section 92C

business of manufacturing and exporting of knitted fabrics/apparels at Brandix APSEZ, Atchutapuram, Visakhapatnam. The assessee filed its return of income for the AY 2016-17 on 30/11/2016 offering gross total income of Rs. 7,79,09,388/-. Out of the gross total income, the assessee claimed deduction u/s. 10AA of the Act and hence the total income declared

GVR POWER & INFRASTRUCTURE LIMITED,KADIYAM vs. ACIT, CIRCLE - 2(1), RAJAHMUNDRY

In the result, the appeal filed by the assessee is partly allowed

ITA 530/VIZ/2017[2013-14]Status: DisposedITAT Visakhapatnam18 May 2018AY 2013-14

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri Deba Kumar Sonowal
Section 92C

Income Tax Act, 1961 (hereinafter called as 'the Act') to Transfer Policy Officer (TPO) for determination of Arms Length Price (ALP) of the tax payer company. The commission charged by the tax payer for corporate guarantee has worked out to 0.90%. The assessee has made the transfer pricing (TP) study and adopted the Comparable Uncontrolled Price (“CUP”) method as most

ASSISTANT COMMISSIONER OF INCOME, CIRCLE-1(1),, GUNTUR vs. M/S CCL PRODUCTS(INDIA) LIMITED, GUNTUR

In the result, appeal of the revenue is dismissed

ITA 348/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam03 Apr 2019AY 2014-15

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.348/Viz/2018 (ननधधारण वर्ा/ Assessment Year:2014-15) Dcit, Circle-1(1) Vs. M/S Ccl Products (India) Guntur Pvt. Ltd. Duggirala Post & Mandal Guntur [Pan : Aaacc9552G] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri D.K.Sonowal, Dr प्रत्यधथी की ओर से/ Respondent By : Shri Ramesh Babu, Ar सुनवधई की तधरीख / Date Of Hearing : 20.03.2019 घोर्णध की तधरीख/Date Of Pronouncement : 03 .04.2019

For Appellant: Shri D.K.Sonowal, DRFor Respondent: Shri Ramesh Babu, AR
Section 92BSection 92C

Income-tax Act, 1961 - Transfer pricing - Computation of arm's length price (Comparables and Adjustments/Adjustments - Interest) - Assessment year 2011-12 - TPO noted that there was delay in receipt of payment from AE and observed that estimate period of 30 days would be considered as normal period for inter-company sales and services and any delay beyond said period should

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 236/VIZ/2020[2016-17]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot