BharatTax.net
SearchITATHigh CourtsSupreme CourtAI 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.

41 results for “transfer pricing”+ Deemed Dividendclear

Sorted by relevance

Mumbai551Delhi208Chandigarh88Hyderabad70Chennai70Cochin65Kolkata44Bangalore42Ahmedabad41Raipur24Jaipur22Pune21Indore11Lucknow11Varanasi5Surat5Rajkot4Visakhapatnam1Guwahati1Jabalpur1Jodhpur1Nagpur1Ranchi1

Key Topics

Section 14A50Section 143(3)43Disallowance31Section 3729Deduction22Addition to Income21Section 80I18Depreciation16Section 4011

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1645/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1644/AHD/2017[2009-10]Status: Disposed

Showing 1–20 of 41 · Page 1 of 3

Section 115J10
Penalty10
Section 43B9
ITAT Ahmedabad
31 Jan 2024
AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1334/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1646/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1335/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1336/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transactions are determined in substance between such other person and the associated enterprise." 12. From the above, it is clear that lending

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

ITA 222/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad21 May 2025AY 2015-16

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144CSection 14ASection 35Section 36(1)(iii)Section 37Section 92C

deemed loan extended to the AEs. Accordingly, the TPO imputed notional interest income by applying LIBOR plus margin, along with an additional 100 basis points for forex risk, resulting in an upward adjustment of Rs.14,64,47,827/-. The assessee contended that receivables are closely linked to the primary international transaction (sale of goods) and are not independent international transactions

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

ITA 281/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad21 May 2025AY 2015-16

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144CSection 14ASection 35Section 36(1)(iii)Section 37Section 92C

deemed loan extended to the AEs. Accordingly, the TPO imputed notional interest income by applying LIBOR plus margin, along with an additional 100 basis points for forex risk, resulting in an upward adjustment of Rs.14,64,47,827/-. The assessee contended that receivables are closely linked to the primary international transaction (sale of goods) and are not independent international transactions

ANMOL HIMANSHU PATEL LEGAL HEIR OF LATE HIMANSHU RAOJIBHAI PATEL,VADODARA vs. THE ITO, WARD-1(1)(4) NOW PRESENT JURISDICTION THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee stands allowed

ITA 1479/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1479/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Anmol Himanshu Patel The Ito बनाम/ (Legal Heir Of Late Himanshu Ward-1(1)(4) V/S. Raojibhai Patel) Now Present Jurisdiction Bs/B-7, Indraprasth Complex The Dy.Cit, Circle-1(1)(1) Nr. Inox Race Course Circle Vadodara – 390 007 Vadodara – 390 007 "थायी लेखा सं./Pan: Acqpp 6460 P (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 09/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/06/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Anmol Himanshu Patel (Legal Heir Of Late Himanshu Raojibhai Patel) Vs. Dcit Asst.Year 2015-16. “1. In Law & In The Facts & Circumstances Of The Case Of The Appellant, The Order Passed By The Cit(A) U/S 250 Of The Act Is Bad In Law & Deserves To Be Quashed.

For Appellant: Shri Biren Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 2(22)(e)Section 250

deemed dividend u/s.2(22)(e) of the Act was not covered in the limited scrutiny assessment in the case of the assessee. The AO did not take permission from the competent authority to cover the said issue or to convert the limited scrutiny into full scrutiny assessment, Anmol Himanshu Patel (Legal Heir of Late Himanshu Raojibhai Patel) vs. DCIT Asst.Year

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

ITA 598/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Oct 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Ms. Chandni Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 143(2)Section 143(3)Section 144C(3)Section 14ASection 195Section 40Section 92C

transfer pricing study, and the AO’s reliance on product-level comparability under CPM was erroneous. Accordingly, ground numbers 1 to 4 of the Revenue are dismissed. Ground No.5 of the Revenue relating to addition made in the book profit u/s 115JB of the Act on account of disallowance u/s 14A of the Act r.w. Rule

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 135/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 134/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 133/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 136/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 150/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 149/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 148/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 147/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 137/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

deemed to be taxed in the hands of the shareholders and it shall not exceed 10 per cent of the gross amount of dividend". That is a provision in the protocol, which is essentially an integral part of the treaty, and the protocol to a treaty is as binding as the provisions in the main treaty itself. In the absence

M/S. SHRI RANG INFRASTRUCTURE PVT. LTD.,,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, appeal of the assessee is partly allowed

ITA 666/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

Section 129Section 142(1)Section 143(1)Section 143(2)Section 44A

price to the land owner in future. The Assessing Officer further observed that while computing the capital gain, the assessee also claimed to have paid Rs.4,11,00,000/- to Kalpesh K. Patel as the confirming party. The assessee was called upon the details vide notice dated 16.03.2016 and the assessee replied vide submissions dated 21.03.2016. The sale deed dated