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979 results for “transfer pricing”+ Section 92Cclear

Sorted by relevance

Mumbai409Delhi266Hyderabad56Kolkata54Bangalore49Chennai36Ahmedabad32Pune22Visakhapatnam11Jaipur10Indore8Dehradun6Surat4Cochin3Nagpur3Cuttack3Raipur2Amritsar2Panaji1Guwahati1Chandigarh1

Key Topics

Transfer Pricing76Section 92C61Section 143(3)60Addition to Income54Comparables/TP36Disallowance35Section 144C(5)22Section 14A20Section 4020Deduction

DCIT, CIRCLE 3(4), MUMBAI, MUMBAI vs. TATA CONSULTANCY SERVICES LIMITED, MUMBAI

ITA 2243/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19
Section 92CSection 92C(3)

transfer pricing adjustments/additions/variations made by the ld.\nAO as being bad in law, illegal and unsustainable on the basis of the following\ngrounds, taken singly or cumulatively:\n2.1.1 a) The Id. AO has failed to comply with the mandatory conditions\nstipulated in section 92C

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 &

Showing 1–20 of 979 · Page 1 of 49

...
20
Double Taxation/DTAA20
Section 144C(13)17
Section 144C
Section 260A
Section 92B
Section 92C
Section 92E

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1058/DEL/2018[2008-09]Status: DisposedITAT Delhi07 Feb 2023AY 2008-09

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. G. C. Srivastava, Adv. &For Respondent: Sh. Bhagwati Charan, Sr. DR
Section 92C

Transfer Pricing Officer (TPO). Sub-section (3) of Section 92CA provides that the TPO, after taking into account the material available with him shall, by an order in writing, determine the ALP in accordance with sub section (3) of Section 92C

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

ITA/1114/2008HC Delhi04 Apr 2013
For Appellant: Ms Suruchii AggarwalFor Respondent: Mr M.S. Syali, Sr. Adv. with Ms Husnal Syali
Section 92C(2)

Transfer Pricing Officer under section 92CA of the said Act for determination of the arm’s length price. At this juncture it would be relevant to note the provisions of section 92C

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 1916/MUM/2024[2012]Status: DisposedITAT Mumbai22 Oct 2024

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

For Appellant: Mr. Rajesh SanghaviFor Respondent: 20/08/2024
Section 271GSection 92Section 92CSection 92D

Section 92C of the Income Tin Act, 1961, for the purpose of determining arm's length price of the Act, 1961, for the purpose of determining arm's length price of the Act, 1961, for the purpose of determining arm's length price of the transaction. Parishi Diamonds 12 CONCLUSION. As the firm has also sold diamonds to independent parties

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)

transfer pricing adjustments/additions/variations made by the ld.\nAO as being bad in law, illegal and unsustainable on the basis of the following\ngrounds, taken singly or cumulatively:\n2.1.1 a) The Id. AO has failed to comply with the mandatory conditions stipulated\nin section 92C

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2004/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer pricing officer under section 92CA (3) of the act dated 27/1/2021 says that reference under section 92C (1) was received

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer pricing officer under section 92CA (3) of the act dated 27/1/2021 says that reference under section 92C (1) was received

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer pricing officer under section 92CA (3) of the act dated 27/1/2021 says that reference under section 92C (1) was received

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2003/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer pricing officer under section 92CA (3) of the act dated 27/1/2021 says that reference under section 92C (1) was received

M/S ISOFT HEALTH MANAGEMENT (INDIA) PVT. LTD.,,CHENNAI vs. DCIT, BANGALORE

In the result, appeal of assessee is allowed

ITA 1210/BANG/2011[2007-08]Status: DisposedITAT Indore21 Aug 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputer Sciences Dcit, Circle 11(4) Corporation India Private No. 14/3, 5Th Floor, R.P. Limited Bhawan Nrupathunga (Formerly Isoft Health Road Vs. Management (India) Pvt. Bangalore Ltd.) Unit-13, Block-2, Sdf Building Mpez Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaco 2465N Assessee By Shri Vishal Kalra, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 03.08.2023 Date Of Pronouncement 21.08.2023

Section 143(3)Section 144C(13)Section 144C(15)(b)Section 144C(5)Section 153(1)Section 92C

price has already been given by the TPO and, therefore, opportunity by the Assessing Officer, for final determination of income under sub-section (4) of section 92C, read with sub- section (4) of section 92CA is to be given by the Assessing Officer. (iv) Maintenance of database: It is to be ensured by the DIT (Transfer

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

ITA 749/PUN/2022[2013-14]Status: DisposedITAT Pune08 Jul 2025AY 2013-14

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Darpan KirpalaniFor Respondent: Shri Madhukar Anand
Section 143(2)Section 92Section 92C

Transfer Price Adjustment was done by the Revenue without having been applied any of the methods prescribed under Section 92C

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

Section 92CSection 92C(3)

transfer pricing adjustments inter-alia states that "by order in writing, determine the arm's length price in relation to the international transaction or specified domestic transaction in accordance with sub-section (3) of section 92C

MONDELEZ INDIA FOODS P.LTD (FORMERLY KNOWN AS CADBURY INDIA LIMITED),MUMBAI vs. ASST CIT RG 5(1)(2), MUMBAI

In the result, appeal filed by the assessee for AY 2013-14 is allowed for statistical purpose

ITA 7104/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Sept 2023AY 2013-14

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14A

price [Others] - Assessment year 2008-09 - Whether while determining ALP of international transactions entered into by assessee, TPO cannot adopt any other method except methods prescribed in section 92C(1) - Held, yes [Para 66] II. Section 92C of the Income-tax Act, 1961 - Transfer

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/110/2014HC Delhi11 Dec 2015
Section 260ASection 92C

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the ALP and make the transfer pricing adjustment by substituting the ALP for the contract price. 63. A reading of the heading of Chapter X ["Computation of income from international transactions having regard to arm's length price"] and Section

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/710/2015HC Delhi11 Dec 2015
Section 260ASection 92C

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the ALP and make the transfer pricing adjustment by substituting the ALP for the contract price. 63. A reading of the heading of Chapter X ["Computation of income from international transactions having regard to arm's length price"] and Section

STAR PAPER MILLS LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 4(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 424/KOL/2022[2018-2019]Status: DisposedITAT Kolkata10 Jul 2023AY 2018-2019

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 424/Kol/2022 Assessment Year: 2018-19 Star Paper Mills Ltd. Dcit, Circle-4(1), Kolkata Duncan House Vs 31, N.S. Road Kolkata - 700001 [Pan : Aaecs0759B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Akkal Dudhewala, Fca Revenue By : Shri G. Hukugha Sema, Cit D/R सुनवाई क" तारीख/Date Of Hearing : 13/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 10/07/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Assistant Commissioner Of Income Tax, Circle- 4(1), Kolkata (Hereinafter The “Ld. Cit(A)”) Dt. 20/06/2022, Passed U/S 144C(13) Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2018-19 Which Is Arising Out Of The Directions Of The Dispute Resolution Panel -2, New Delhi (Hereinafter Referred To As The ‘Ld. Drp) U/S 144C(5) Of The Act Dt. 29/04/2022. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That On The Facts & In The Circumstances Of The Case & In Law, The Ao/Tpo In Complete Disregard Of The Binding Precedent In Assessee'S Own Case For 2

For Appellant: Shri Akkal Dudhewala, FCAFor Respondent: Shri G. Hukugha Sema, CIT D/R
Section 144C(13)Section 144C(5)Section 80Section 92B

section 92C, the arm's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely: (a) comparable uncontrolled price method, by which,-- (i) the price charged or paid for property transferred

MONDELEZ INDIA FOODS P.LTD,MUMBAI vs. ASST CIT RG 5(1)(2), MUMBAI

ITA 1518/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Aug 2023AY 2012-13

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

price [Others] - Assessment year 2008-09 - Whether while determining ALP of international transactions entered into by assessee, TPO cannot adopt any other method except methods prescribed in section 92C(1) - Held, yes [Para 66] II. Section 92C of the Income-tax Act, 1961 - Transfer

MONDELEZ INDIA FOODS P. LTD,MUMBAI vs. DCIT RG 5(1)(2), MUMBAI

ITA 1240/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Aug 2023AY 2011-12

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

price [Others] - Assessment year 2008-09 - Whether while determining ALP of international transactions entered into by assessee, TPO cannot adopt any other method except methods prescribed in section 92C(1) - Held, yes [Para 66] II. Section 92C of the Income-tax Act, 1961 - Transfer