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.

17 results for “transfer pricing”+ Section 111clear

Sorted by relevance

Mumbai273Delhi225Chennai83Bangalore73Hyderabad71Cochin57Jaipur54Chandigarh28Kolkata26Rajkot19Indore19SC18Raipur17Ahmedabad17Agra14Pune13Jodhpur12Visakhapatnam11Lucknow10Cuttack9Nagpur7Surat5Allahabad3Dehradun1Amritsar1Ranchi1D.K. JAIN JAGDISH SINGH KHEHAR1

Key Topics

Section 14A37Disallowance13Section 153A12Addition to Income12Section 1477Survey u/s 133A7Section 115J6Section 133A6Section 132

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 392/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Mukesh Patel, Shri Ajit KumarFor Respondent: Shri Prathvi Raj Meena, CIT.DR
Section 153(4)Section 153CSection 35Section 35(1)(i)Section 35(1)(iv)Section 92CSection 92C(2)

Section 92B of the Act between the assessee and its associate enterprise were given in Form 3ECB and the aggregate value of the international transactions mentioned therein was Rs.21,54,00,08,465/-. A reference u/s.92CA(1) of the Act was sent by the AO to the TPO to determine the Arm’s Length Price of the international transactions undertaken

6
Section 139(1)6
Depreciation6
Cash Deposit6

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

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

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Officer (Ld TPO) under the directions of Honourable Dispute Resolution Panel (Hon’ble DRP), erred in making an upward adjustment of Rs 2.22 61.539/- in relation to the international transaction of payment of Infrastructure Consultancy and support charges to Associated Enterprise (AE) The Appellant prays that the addition made by the Ld AO TPO in relation

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

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

ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Officer (Ld TPO) under the directions of Honourable Dispute Resolution Panel (Hon’ble DRP), erred in making an upward adjustment of Rs 2.22 61.539/- in relation to the international transaction of payment of Infrastructure Consultancy and support charges to Associated Enterprise (AE) The Appellant prays that the addition made by the Ld AO TPO in relation

JIGNASA ATULKUMAR SHAH,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

ITA 1140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 10(38)Section 147Section 148Section 69Section 69A

Transfer Pricing Officer, as the case may be] had been the subject matter of any appeal filed on or before or after the 1st day of June 1988 the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as hail not been considered and decided

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 198/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 199/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 1172/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad26 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Vartik Choksi, With Shri DhrunalBhatt, ARsFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 14ASection 35Section 43BSection 80

transfer pricing on account of capital account transaction being the acquisition of shares. Merely, there was a delay in the allotment of shares by the AE to the assessee, such delay cannot change the character of the transaction as loan. We note that the Delhi bench of ITAT in the case of Bharti Airtel Limited vs. ACIT reported

SWASTIK DEVELOPERS,AHMEDABAD vs. THE INCOME TAX OFFICER WARD 3(3)(5), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 955/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Aug 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2017-2018 Swastik Developers The Ito, Ward-3(3)(5), 21, Swastik House Vs. Ahmedabad. B/H.Sardar Patel Stadium Ahmedabad. Pan : Acyfs 0641 R (Applicant) (Responent) : Shri Prashant Shrivastav, Ar Assessee By : Shri Hargovind Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/08/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/08/2025

For Appellant: Shri Hargovind Singh, Sr.DR
Section 144BSection 147Section 148Section 148ASection 250Section 68Section 69

transferring the money to the firm. The partners’ returned incomes were 4 found to be disproportionately low vis-à-vis the capital introduced. The AO held that in the absence of satisfactory explanation, the investment of Rs.2,91,23,300/- remained unexplained under section 69, and the capital of Rs.1,37,40,714/- introduced by the remaining ten partners (except

GUJARAT INDUSTRIES POWER CO.LTD.,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

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

ITA 3049/AHD/2010[1998-99]Status: DisposedITAT Ahmedabad15 Mar 2024AY 1998-99

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 3049 & 3050/Ahd/2010 धििाधरणवरध/Asstt. Years: (1998-1999 & 1999 & 2000) Gujarat Industries Power Company The Asst. Commissioner Of Ltd., Vs. Income Tax, P.O Petrochemicals, Circle-1(1), Baroda-391346. Baroda.

For Appellant: Shri Yogesh Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 147Section 148

price of the land which was to be actually paid from the collections received by the firm from membership fees as soon as received, as was envisaged admittedly in paragraph 11 of the partnership deed, there was no question of any change of opinion wheri on the relevant facts being found the Assessing Officer while protectively assessing the petitioner-assessee

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

ITA 921/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

ITA 975/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

ITA 976/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

ITA 977/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

ITA 978/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

ITA 920/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 133ASection 139(1)Section 153A

111 ITR 263 (SC)]. e] The two requisites are (a) the loss is incidental to trade itself, that is to say, there must be a nexus between the loss and the trade which should have been incurred in the course of the trade and (b) the loss should have been incurred by one in the character of a trader