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11 results for “transfer pricing”+ Section 115Jclear

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Key Topics

Section 14A50Section 115J20Section 143(3)14Section 8011Disallowance10Depreciation4Addition to Income4Deduction3Section 80I2Section 263

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

ITA 805/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2012-13

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

115J." The Court declines to frame a question on the above issue." 21. Apart from the above, we have a binding precedent before us - One from Hon’ble jurisdictional High Court and other from the Hon’ble Bombay High court. The question considered by the Hon’ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

2
Section 14A(2)2
Section 143(2)2

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

ITA 2744/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2013-14

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

115J." The Court declines to frame a question on the above issue." 21. Apart from the above, we have a binding precedent before us - One from Hon’ble jurisdictional High Court and other from the Hon’ble Bombay High court. The question considered by the Hon’ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

GUJARAT ALKALIES AND CHEMICALS LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BARODA

In the result the appeal filed by the Revenue is dismissed

ITA 1455/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad16 Oct 2019AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Sulabh Padshah, A.RFor Respondent: Shri O. P. Sharma, CIT-D.R
Section 115JSection 143(3)Section 80Section 80I

transfer is by eligible business to another non eligible business of the same assessee and the consideration recorded in the accounts of the eligible business does not correspond to market value of such goods. Term "Market Value" is further explained in explanation to said sub-section to mean in relation to any goods or services, price that such goods

THE DCIT, CIRCLE-1(1)(1),, VADODARA vs. M/S. GUJARAT ALKALIES & CHEMICALS LTD.,, VADODARA

In the result the appeal filed by the Revenue is dismissed

ITA 1589/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad16 Oct 2019AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Sulabh Padshah, A.RFor Respondent: Shri O. P. Sharma, CIT-D.R
Section 115JSection 143(3)Section 80Section 80I

transfer is by eligible business to another non eligible business of the same assessee and the consideration recorded in the accounts of the eligible business does not correspond to market value of such goods. Term "Market Value" is further explained in explanation to said sub-section to mean in relation to any goods or services, price that such goods

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

115J.” The Court declines to frame a question on the above issue.” 21. Apart from the above, we have a binding precedent before us – one from Hon'ble jurisdictional High Court and other from the Hon'ble Bombay High Court. The question considered by the Hon'ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

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

115J.” The Court declines to frame a question on the above issue.” 21. Apart from the above, we have a binding precedent before us – one from Hon'ble jurisdictional High Court and other from the Hon'ble Bombay High Court. The question considered by the Hon'ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

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

115J.” The Court declines to frame a question on the above issue.” 21. Apart from the above, we have a binding precedent before us – one from Hon'ble jurisdictional High Court and other from the Hon'ble Bombay High Court. The question considered by the Hon'ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

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

115J.” The Court declines to frame a question on the above issue.” 21. Apart from the above, we have a binding precedent before us – one from Hon'ble jurisdictional High Court and other from the Hon'ble Bombay High Court. The question considered by the Hon'ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

GUJARAT FLUOROCHEMICALS LIMITED.,,VADODARA vs. THE DCIT, CIRCLE-1(1)(1),, VADODARA

The appeal of the assessee is partly allowed

ITA 751/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad28 Dec 2022AY 2014-15

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar"नधा"रणवष"/Assessment Year: 2014-15 Gujarat Fluorochemicals Ltd., Vs. Dcit, 2Nd Floor, Abs Tower, Old Circle 1(1)(1), Padra Road, Baroda-390007 Baroda Pan : Aaacg 6725 H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Revenue By : Shri Samir Tekriwal, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 11.10.2022 घोषणा क" तार"ख /Date Of Pronouncement: 28.12.2022 आदेश/O R D E R Per Annapurna Gupta:

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri Samir Tekriwal, CIT-DR
Section 115Section 115JSection 14ASection 14A(2)Section 8D(2)(i)

115J." The Court declines to frame a question on the above issue." 21. Apart from the above, we have a binding precedent before us - one from Hon’ble jurisdictional High Court and other from the Hon’ble Bombay High Court. The question considered by the Hon’ble Gujarat High Court in the case of Alembic Ltd. (supra) is as under

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

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1,, BARODA

In the result, appeal filed by the assessee is allowed

ITA 903/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2011-12

Bench: The Itat. Considering The Same, The Order Passed By Itat Was Recalled & The Appeal Of The Assessee Fixed For Adjudication Afresh On Merits, Vide Order In Ma No.94/Ahd/2025, Dated 18.12.2025. The Present Appeal, Accordingly, Has Come Up For Hearing Before Us.

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Alpesh Parmar, CIT.DR
Section 115JSection 143(3)Section 263

Section 263 of the ITA No.903/Ahd/2016 [Ambalal Sarabhai Enterprises Ltd. vs. PCIT] A.Y. 2011-12 - 2 – Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2011-12. 2. The order in the present appeal was originally passed vide order dated 25.06.2025 dismissing the appeal as infructuous noting that no consequential order had been