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16 results for “transfer pricing”+ Natural Justiceclear

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Key Topics

Section 2638Section 80I7Section 143(3)6Addition to Income5Section 143(2)4Section 92C4Section 142(1)3Section 1473Section 153C

KOTARI SRINIVASA RAO, ,UNDRAJAVARAM MANDALAM vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, , RAJAHMUNDRY

In the result, additional ground raised is allowed

ITA 335/VIZ/2019[2014-15]Status: DisposedITAT Visakhapatnam20 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.335/Viz/2019 (ननधधारण वर्ा / Assessment Year : 2014-15) Kotari Srinivasa Rao Vs. Principal Commissioner Of D.No.1-91, Canal Road Income Tax Velivennu Rajahmundry Undrajavaram Mandal West Godavari Dist. [Pan : Apjpk9870N] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri Md.Afzal,ARFor Respondent: Dr.Satyasai Rath, CIT(DR)
Section 143(3)Section 263

nature, we are inclined to admit the additional ground in the interest of justice. 6. At the outset, the Ld.AR has submitted that the assessee raised additional ground saying that issuance of order u/s 263 of the Act was only on the recommendation of the Ld.AO which is not permissible under law and he has also relied on the decision

3
Disallowance2
Transfer Pricing2
Comparables/TP2

DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

ITA 354/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

Section 144C(3)Section 147Section 148Section 153CSection 69A

transfer of 1,06,900 shares by the assessee at Rs. 657 per share for a total consideration of Rs. 7,02,33,300. 4. On the other hand, the seized scribbling contained entries which the department construed as cash payments to certain persons, including the assessee. The noting in the seized scribblings mentioned, viz. “18/08/2015 – 100 cash Appa

BRANDIX APPARAL INDIA PRIVATE LIMITED,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 5(1), VISAKHAPATNAM

In the result, appeal of the assessee is partly allowed for

ITA 627/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam13 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No.627/Viz/2018 ("नधा"रणवष"/ Assessment Year : 2014-15) Brandix Apparel India Private Vs. Assistant Commissioner Of Limited, Income Tax, Apsez, Pudimadaka Road, Circle-5(1), Atchutapuram Mandal, Visakhapatnam. Visakhapatnam – 530011. Pan: Aaccb 6569 L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Sri Darpan Kriplani ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri Darpan KriplaniFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 142(1)Section 143(2)Section 143(3)Section 92C

transfer price of processing services the Ld. DRP / AO / TPO erred in 4.1. Rejecting the TP documents maintained by the appellant U/s. 92D of the Act in good faith and with due diligence. 4.2. Rejecting the comparability analysis carried out by the assessee in TP documentation and in conducting a fresh comparability analysis for processing services. 4.3. Not providing

QUANTUM CLOTHING INDIA PRIVATE LIMITED, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1),, VISAKHAPATNAM

In the result, appeal of the assessee is allowed for statistical purposes

ITA 603/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam16 Feb 2023AY 2014-15

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

For Appellant: Sri R. VijayaraghavanFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 92CSection 92C(3)

Transfer Pricing Officer [TPO], Hyderabad after taking necessary approval from the Principal Commissioner of Income Tax-2, Visakhapatnam for determining the Arm’s Length Price [ALP] u/s. 92CA(1) of the Act. After providing an opportunity to the assessee, the Ld. TPO passed the order U/s. 92CA(3) of the Act on 31/10/2017 determining the adjustment U/s. 92CA

NEKKANTI SEA FOODS LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME-TAX, VISAKHAPATNAM

In the result, appeal of the assessee is dismissed

ITA 223/VIZ/2023[2019-2020]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2019-2020
Section 143(1)Section 143(2)Section 143(3)Section 80I

justice and equity.”\n5.\nThe only issue emanating from the grounds raised by the assessee is with\nrespect to disallowance of claim made u/s. 80IB of the Act amounting to\nRs.38,75,92,325/-.\n6.\nOn this issue Ld. Authorised Representative [hereinafter “Ld.AR"]\nsubmitted that the provisions of section 80IB of the Act states that \"profits\nderived from the business

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

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

ITA 396/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

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

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

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

ITA 25/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

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

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

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

ITA 399/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

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

ITA 12/VIZ/2015[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

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

ITA 325/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2012-2013

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

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 235/VIZ/2020[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

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

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

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

ITA 397/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

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

ITA 26/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

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

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

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

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

ITA 49/VIZ/2021[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

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

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

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

ITA 67/VIZ/2021[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