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7,171 results for “transfer pricing”+ Business Incomeclear

Sorted by relevance

Mumbai2,155Delhi1,879Chennai472Hyderabad406Bangalore406Ahmedabad276Jaipur227Kolkata223Chandigarh166Pune153Indore126Cochin123Rajkot95Surat81Visakhapatnam67Nagpur47Raipur44Lucknow39Cuttack36Amritsar28Guwahati26Jodhpur23Agra21Dehradun12Patna9Jabalpur8Varanasi7Panaji7Allahabad5Ranchi4

Key Topics

Section 143(3)79Addition to Income61Transfer Pricing48Section 92C41Section 80I38Deduction35Disallowance33Section 14A32Section 143(2)25Section 10(38)

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 133(6)Section 92D

pricing order passed by Additional Commissioner of\nIncome-tax (Transfer Pricing) - 1(3), Mumbai is beyond jurisdiction -\nThe ground was not pressed\n1. Reference to the Additional Commissioner of Income-Tax (Transfer\nPricing) - 1(3), Mumbai and the transfer pricing order under section\n92CA(3) of the Act passed by the Additional Commissioner of Income-Tax\n(Transfer Pricing

ACIT CIRCLE 5(1)(1), MUMBAI vs. M/S ESSAR SHIPPING LIMITED, MUMBAI

In the result, appeal filed by the learned AO is dismissed

ITA 2951/MUM/2022[2015-2016]Status: DisposedITAT Mumbai09 Jan 2024AY 2015-2016

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm M/S Essar Shipping Limited Acit, Circle 5(1)(1) Essar House, 11, R.No.568, Aaykar Bhavan, Vs. Kk Marg, Mahalaxmi, M.K. Road, Mumbai-400 020 Mumbai-400 034 (Appellant) (Respondent) Pan No. Aacce3707D

Showing 1–20 of 7,171 · Page 1 of 359

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25
Section 3524
Section 26319
For Appellant: Shri Rishav Patawari, ARFor Respondent: Shri Manoj Sinha, CIT DR
Section 115VSection 143Section 144CSection 28Section 43Section 92Section 92CSection 92F

transfer pricing provisions envisage computation of income from specified international transactions of receipt or expenditure, ofcourse with reference to the stated price of such transactions. This is completely in contrast to Chapter-XII G, where the stated price of the transaction has no relevance to the computation of income of qualifying ships, which is based on the weight

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3396/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Sept 2025AY 2014-15
For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)
Section 143(3)Section 148Section 22Section 24

price in respect thereof.\nb. The developer received the possession of the land which is constructed the\nimpugned building. The date, on which the assessee received the possession of the\nland, there is a transfer of the land within the meaning of Section 2(47)(v) and the\nassessee becomes the owner of the land and building thereon constructed

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1 , KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3395/MUM/2024[2012-13]Status: DisposedITAT Mumbai09 Sept 2025AY 2012-13
For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)
Section 143(3)Section 148Section 22Section 24

price in respect thereof.\nb. The developer received the possession of the land which is constructed the\nimpugned building. The date, on which the assessee received the possession of the\nland, there is a transfer of the land within the meaning of Section 2(47)(v) and the\nassessee becomes the owner of the land and building thereon constructed

ARIHANT DEVELOPERS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3397/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Sept 2025AY 2015-16
For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)
Section 143(3)Section 148Section 22Section 24

price in respect thereof.\nb. The developer received the possession of the land which is constructed the\nimpugned building. The date, on which the assessee received the possession of the\nland, there is a transfer of the land within the meaning of Section 2(47)(v) and the\nassessee becomes the owner of the land and building thereon constructed

COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

ITA/938/2011HC Delhi28 Nov 2011
For Appellant: Ms Suruchi AggarwalFor Respondent: Mr M.S. Syali, Sr. Advocate with Mr Mayank Nagi &
Section 144CSection 260ASection 92BSection 92CSection 92E

Transfer Pricing Officer (TPO) could not take cognizance suo moto of any international transaction for adjustment in the Arms Length Price (ALP) under Section 92CA of the Income-tax Act, 1961?” 2011:DHC:6027-DB ITA 938/11 Page 2 of 20 2. The facts of the case are that the assessee, which was incorporated on 26.07.1999 as a joint venture

M/S. ESSAR SHIPPING LTD,MUMBAI vs. DCIT, CIRCLE 5(1)(1), MUMBAI

In the result, the appeal of the assessee is In the result, the appeal of the assessee is dismissed

ITA 6521/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 May 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2021-22 M/S Essar Shipping Ltd., Dy. Cit, Circle 5(1)(1), 5Th Floor, Essar House, 11, Keshav Mumbai/Assessment Unit, Vs. Rao Khadye Marg, Mahalaxmi National Faceless Assessment Mumbai-400034. Centre, Room No. 568, Aayakar Bhavan, M.K. Road, Mumbai-400020. Pan No. Aacce 3707 D Appellant Respondent

For Appellant: Mr. Suresh Gaikwad, Sr. DRFor Respondent: Mr. Piyush Chaturvedi
Section 115B

business has been offered under the normal provisions of the Act. The return of income filed under the normal provisions of the Act. The return of income filed under the normal provisions of the Act. The return of income filed by the assessee was selected for scrutiny by the assessee was selected for scrutiny assessment assessment and statutory M/s Essar

ARIHANT DEVELOPERS ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -1, KALYAN

In the result, all the above appeals of the assessee are\ndismissed

ITA 3398/MUM/2024[2017-18]Status: DisposedITAT Mumbai09 Sept 2025AY 2017-18
For Appellant: \nShri K. Gopal & Akhilesh Deshmukh, ARsFor Respondent: \nShri Aditya Rai (Sr. DR)
Section 143(3)Section 148Section 22Section 24

price in respect thereof.\nb. The developer received the possession of the land which is constructed the\nimpugned building. The date, on which the assessee received the possession of the\nland, there is a transfer of the land within the meaning of Section 2(47)(v) and the\nassessee becomes the owner of the land and building thereon constructed

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

income of the assessee at ₹ 72,277,598/- against the return filed by the assessee of ₹ 44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

income of the assessee at ₹ 72,277,598/- against the return filed by the assessee of ₹ 44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

income of the assessee at ₹ 72,277,598/- against the return filed by the assessee of ₹ 44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer

M/S SUPREMO INDIA LTD ,INDORE vs. THE AIT CENTRAL 3, INDORE

In the result, appeal of assessee is allowed

ITA 29/IND/2023[2019-20]Status: DisposedITAT Indore07 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Supremo India Pvt. Ltd. Acit Central-3 400/2, Halka Patwari No.52 Indore Vs. Badiakeema Dudhiya, B.O. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcs 9822 C Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 07.06.2023

Section 115BSection 131(1)Section 133ASection 69ASection 69B

business income”. The view so taken by the Assessing officer is after due application of mind and therefore cannot be held as unsustainable in the eyes of law. In the facts and circumstances of the present case, where there are specific questions asked during the course of survey regarding the nature and source of income and which has been adequately

CARGILL INTERNATIONAL TRADING PTE LTD.,SINGAPORE vs. ACIT CIRCLE INTL. TAXATION 1(2)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2358/DEL/2023[2020-21]Status: DisposedITAT Delhi18 Dec 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 115ASection 143(2)Section 143(3)Section 9(1)(i)

transfer of a capital asset situate in India. 16. Accordingly, the ld. counsel for the assessee submitted that the payer, Adani Wilmar, is only source of money received and not source of income. The source of income is dependent on the activities with respect to where the activities, with respect to those transactions, take place. Reliance in this regard

M/S NIKHIL ESTATE P LTD,INDORE vs. THE ACIT CENTRAL CIRCLE (3) INDORE, INDORE

In the result, appeal of assessee is allowed

ITA 28/IND/2023[2019-20]Status: DisposedITAT Indore09 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Nikhil Estate Pvt. Ltd. Acit (Central)-3 M-102, Mezzanine, Floor, Indore Dhan Trident, P. No.B-3 Pu- Vs. 4, Sch. No.54, Vijay Nagar Square, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcn 8056 D Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 09.06.2023

Section 115BSection 133ASection 69Section 69B

business income”. The view so taken by the Assessing officer is after due application of mind and therefore cannot be held as unsustainable in the eyes of law. In the facts and circumstances of the present case, where there are specific questions asked during the course of survey regarding the nature and source of income and which has been adequately

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

Income Tax of the Delhi High Court). Five Methods 65. Comparable Uncontrolled Price Method (‗CUP Method‘, for short) compares price charged for the property or service in a controlled transaction with the price charged for comparable property or service in an uncontrolled transaction in comparable circumstances. In RP Method, the price paid for the product by an independent third party

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

transfer of cash to such unexplained advances. If the undisclosed income earned and accumulated over the years is taxed in the year in which it is detected by the Revenue and the same is merely taxed as per normal provisions of the law such an interpretation will place a premium on dishonesty i.e. it tantamounts to rewarding the dishonesty. There

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

ITA 1516/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Dec 2025AY 2016-17
Section 92CSection 92C(3)

income is expected to be\ngenerated from the same.\n21. Grounds taken by Revenue are reproduced as under:\nITA No. 2243/MUM/2025\nGrounds no. 1 to 3 are related to Transfer Pricing\nOn the issue of Provision of Software, Technical and Consultancy Services:\n1.1 Whether on the facts and circumstances of the case

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

ITA 285/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 Nov 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –
Section 132Section 132(4)Section 143(3)Section 153A

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

ITA 287/CHNY/2024[2019-20]Status: DisposedITAT Chennai26 Nov 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –
Section 132Section 132(4)Section 143(3)Section 153A

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

ITA 283/CHNY/2024[2015-16]Status: DisposedITAT Chennai26 Nov 2024AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. R. Clement Ramesh –
Section 132Section 132(4)Section 143(3)Section 153A

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from