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91 results for “transfer pricing”+ Reopening of Assessmentclear

Sorted by relevance

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Key Topics

Section 14775Section 143(3)69Addition to Income64Section 153A44Section 26341Section 14840Section 14A38Disallowance35Section 153C

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1596/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reopening of reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

Showing 1–20 of 91 · Page 1 of 5

26
Section 13224
Penalty21
Reassessment17

In the result, Ground Nos

ITA 1594/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad31 May 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reopening of reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1595/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reopening of reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities

JET AIR AGENCIES PVT LTD,WEST BENGAL vs. CENTRAL CIRCLE 2(3)AHMEDABAD, AHMEDABAD

In the result, Ground Nos

ITA 685/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reopening of reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1597/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

reopening of reassessment is liable to be dismissed. On Merits (A.Y. 2010-11) 13. The additions have been made by the AO on primarily two counts for the impugned year under consideration. Firstly, the AO observed that during the year under consideration, the assessee was engaged in providing contrived losses to various parties on sale of certain illiquid commodities

HASMUKH UGARCHAND GADHECHA, HUF,AHMEDABAD vs. THE ITO, WARD-5(2)(2), AHMEDABAD

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 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 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR
Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

reopened u/s.147 of the Act by way of issuance of notice dated 30/03/2021 u/s.148 of the Act. 4.1. The reasons for re-opening of the assessment were that a search and survey action was carried out at the residence and office premises of one Shri Shirish Chandra Shah and at the residence of his key-employees and associates on 09/04/2013

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

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

ITA 54/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Section 143(3)Section 147Section 148Section 14ASection 35Section 36(1)(iii)Section 36(1)(vii)Section 37(1)Section 80I

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

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

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

ITA 1867/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Section 143(3)Section 147Section 148Section 14ASection 35Section 36(1)(iii)Section 36(1)(vii)Section 37(1)Section 80I

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 45/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

transfers, RTGS, and clearings in various bank accounts of the HUF, with no explanation or supporting evidence. Further, the Assessing Officer observed that the assessee had given a loan of Rs. 1,27,75,176/- to SBPL Finance, which is a non-filer with no return of income filed, and also a loan of Rs. 18,30,000/- to Shreeji

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 47/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

transfers, RTGS, and clearings in various bank accounts of the HUF, with no explanation or supporting evidence. Further, the Assessing Officer observed that the assessee had given a loan of Rs. 1,27,75,176/- to SBPL Finance, which is a non-filer with no return of income filed, and also a loan of Rs. 18,30,000/- to Shreeji

INCOME TAX WARD 4(2)(3) AHMEDABAD , AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

ITA 266/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

transfers, RTGS, and clearings in various bank accounts of the HUF, with no explanation or supporting evidence. Further, the Assessing Officer observed that the assessee had given a loan of Rs. 1,27,75,176/- to SBPL Finance, which is a non-filer with no return of income filed, and also a loan of Rs. 18,30,000/- to Shreeji

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 46/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2015-16

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

transfers, RTGS, and clearings in various bank accounts of the HUF, with no explanation or supporting evidence. Further, the Assessing Officer observed that the assessee had given a loan of Rs. 1,27,75,176/- to SBPL Finance, which is a non-filer with no return of income filed, and also a loan of Rs. 18,30,000/- to Shreeji

INCOME TAX WARD 4(2)(3) AHMEDABAD, AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

ITA 267/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

transfers, RTGS, and clearings in various bank accounts of the HUF, with no explanation or supporting evidence. Further, the Assessing Officer observed that the assessee had given a loan of Rs. 1,27,75,176/- to SBPL Finance, which is a non-filer with no return of income filed, and also a loan of Rs. 18,30,000/- to Shreeji

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

ITA 248/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2014-15

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agrawal & Shri S.V. AgrawalFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 127Section 132Section 133ASection 139(1)Section 147Section 153CSection 234BSection 44A

reopening of assessee's assessment was bad in law. Accordingly, looking into the instant facts, where the Ld. Assessing Officer proceeded to make additions in the hands on account of undisclosed investments on the basis of documents found during the course of search at third party premises, in our view, the correct course should have been to initiate proceedings under

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

ITA 250/AHD/2023[2019-20]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2019-20

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agrawal & Shri S.V. AgrawalFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 127Section 132Section 133ASection 139(1)Section 147Section 153CSection 234BSection 44A

reopening of assessee's assessment was bad in law. Accordingly, looking into the instant facts, where the Ld. Assessing Officer proceeded to make additions in the hands on account of undisclosed investments on the basis of documents found during the course of search at third party premises, in our view, the correct course should have been to initiate proceedings under

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

ITA 249/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2016-17

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agrawal & Shri S.V. AgrawalFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 127Section 132Section 133ASection 139(1)Section 147Section 153CSection 234BSection 44A

reopening of assessee's assessment was bad in law. Accordingly, looking into the instant facts, where the Ld. Assessing Officer proceeded to make additions in the hands on account of undisclosed investments on the basis of documents found during the course of search at third party premises, in our view, the correct course should have been to initiate proceedings under

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

ITA 325/AHD/2023[2016-2017]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2016-2017

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agrawal & Shri S.V. AgrawalFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 127Section 132Section 133ASection 139(1)Section 147Section 153CSection 234BSection 44A

reopening of assessee's assessment was bad in law. Accordingly, looking into the instant facts, where the Ld. Assessing Officer proceeded to make additions in the hands on account of undisclosed investments on the basis of documents found during the course of search at third party premises, in our view, the correct course should have been to initiate proceedings under

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

ITA 326/AHD/2023[2019-2020]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2019-2020

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agrawal & Shri S.V. AgrawalFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 127Section 132Section 133ASection 139(1)Section 147Section 153CSection 234BSection 44A

reopening of assessee's assessment was bad in law. Accordingly, looking into the instant facts, where the Ld. Assessing Officer proceeded to make additions in the hands on account of undisclosed investments on the basis of documents found during the course of search at third party premises, in our view, the correct course should have been to initiate proceedings under

BHAMIRABEN PRASHANTKUMAR PATEL,ANAND vs. THE INCOME TAX OFFICER, WARD-1, ANAND

In the result, the appeal of the assessee stands allowed

ITA 654/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad15 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.654/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhamiraben Prashantkumar Patel The Income Tax Officer बनाम/ 14, Vaividhya Bungalows Ward-1 V/S. Dr. H.M. Patel Anand – 388 001 Anand Vallabh Vidhyanagar Road, Anand – 388 001 (Gujarat) "थायी लेखा सं./Pan: Azcpp 7413 M (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Aseem L. Thakkar, Ar Revenue By : Shri Rajeev Garg, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 15/12/2025 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Rajeev Garg, Sr.DR
Section 147Section 250Section 69A

assessment order) were found guilty and the SEBI had levied penalty of Rs.20 lakhs each to the said violators. The AO further observed that even, thereafter, the SEBI had passed one more order dated 31/05/2019 against other 14 persons, who were indulged in price rigging in the scrip price of Kushal Tradelink Ltd., imposing penalty of Rs.3

VEENITA ENTERPRISE PVT. LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1),, AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

ITA 1199/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad14 Jun 2024AY 2009-10

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

Section 132(4)Section 143(3)Section 147Section 148Section 68

reopen the assessment. 11. In the case of Purviben Snehalbhai Panchhigar [2019] 101 taxmann.com 393 (Gujarat), the Gujarat High Court held that in the instant case the Assessing Officer has heard the material on record which would prima- facie suggest that the assessee had sold number of shares of a company which was found to be indulging in providing bogus