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.

21 results for “transfer pricing”+ Section 12(1)(ac)clear

Sorted by relevance

Delhi206Hyderabad138Mumbai128Chandigarh66Chennai40Kolkata24Ahmedabad21Guwahati16Bangalore12Pune10Dehradun8Jaipur8Rajkot6Visakhapatnam4Agra3Cochin3Surat3Nagpur2Jodhpur1Indore1

Key Topics

Section 8024Section 143(3)16Addition to Income13Section 12A9Section 11(4)8Section 118Section 80G(5)7Section 92C6Deduction6

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

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

Section 143(3)Section 80ISection 92BSection 92C

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

Showing 1–20 of 21 · Page 1 of 2

Exemption6
Section 56(2)(x)5
Depreciation4
ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

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

Section 143(3)Section 80ISection 92BSection 92C

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

SHREE AATH PARAGANA GURJAR PRAJAPATI SAMAJ TRUST,AHMEDABAD vs. CIT(EXEMPTION), AHMEDABAD, VEJALPUR, AHMEDABAD

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

ITA 2025/AHD/2024[N.A.]Status: DisposedITAT Ahmedabad12 Aug 2025

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : - Shree Aath Paragana Gurjar Prajapati The Cit(Exemption) Samaj Trust Vs. Vejalpur Prajapati Bhavan Chatrala Ahmedabad. Sola Railway Over Bridge Naittar Chede, Sola Ghatlodia. Pan : Abfts 9086 E (Applicant) (Responent) : Assessee By Shri Prakash D. Shah & Shri Saiyam Shah, Ar : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

Section 12ASection 12A(1)(ac)

transfer pricing deadlines, as well as the intervening Diwali holidays, the filing of the appeal was inadvertently delayed. The assessee has specifically affirmed that there was no intention to delay the proceedings or prejudice the interest of the Revenue, and that the delay was neither wilful nor deliberate but occurred due to genuine professional and logistical constraints. In the accompanying

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 829/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 830/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 2498/AHD/2013[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 828/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

RABDI VIBHAG PROGRESSIVE KELAVNI MANDAL,VALSAD vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 797/AHD/2023[NA]Status: DisposedITAT Ahmedabad24 Jan 2024

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(iv)

ac) of sub-section (1) of section 122A of the Act, till 30.09.2023 where the due date for making such application has expired prior to such date. 15. However, in earlier Circular 8/2022, which was issued on 31.03.2022 the CBDT has given instruction about approval 80G(5) of the Act, which is reproduced below: “1. On consideration of difficulties

N K PROTEINS PVT. LIMITED,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), AHMEDABAD

In the result, no question of law arises

ITA 464/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri V. Nandakumar, CIT-DR
Section 142Section 143(1)Section 143(3)Section 250Section 36(1)(va)

transfer of the commodity or scrips: Provided that for the purposes of this clause— (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. N K PROTEINS PRIVATE LIMITED, AHMEDABAD

In the result, no question of law arises

ITA 546/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri V. Nandakumar, CIT-DR
Section 142Section 143(1)Section 143(3)Section 250Section 36(1)(va)

transfer of the commodity or scrips: Provided that for the purposes of this clause— (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

DCIT(E), CIRCLE-1, AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 21/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R
Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

1 of the assessee. 8.11 The crux of the decision is that even if a business undertaking is a property of the trust but if the business carried on is not meant to fulfill the objects of the trust, then also such a business income is out of the exemption clause We think this is the purpose of the enactment

DCIT (EXMP) CIRCLE-1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 22/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R
Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

1 of the assessee. 8.11 The crux of the decision is that even if a business undertaking is a property of the trust but if the business carried on is not meant to fulfill the objects of the trust, then also such a business income is out of the exemption clause We think this is the purpose of the enactment

DCIT(EXEMPTION) CIRCLE-1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 23/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R
Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

1 of the assessee. 8.11 The crux of the decision is that even if a business undertaking is a property of the trust but if the business carried on is not meant to fulfill the objects of the trust, then also such a business income is out of the exemption clause We think this is the purpose of the enactment

DCIT (EXMP) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 20/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R
Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

1 of the assessee. 8.11 The crux of the decision is that even if a business undertaking is a property of the trust but if the business carried on is not meant to fulfill the objects of the trust, then also such a business income is out of the exemption clause We think this is the purpose of the enactment

THE VARDHMAN STAMPINGS PVT. LTD.,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD

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

ITA 363/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2015-16
Section 263Section 43(5)Section 73

1-4-2006.\nIt lays down that any 'eligible transaction' in respect of trading in derivatives referred\nto in clause (ac) of section 2 of the Securities Contracts (Regulation) Act, 1956, that\nhas been carried out in a recognized stock exchange shall not be treated as a\nspeculative transaction. Further, an 'eligible transaction' for this purpose would be\none that

THE VARDHMAN STAMPINGS PVT. LTD.,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD

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

ITA 362/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2014-15
Section 263Section 43(5)Section 73

1-4-2006.\nIt lays down that any 'eligible transaction' in respect of trading in derivatives referred\nto in clause (ac) of section 2 of the Securities Contracts (Regulation) Act, 1956, that\nhas been carried out in a recognized stock exchange shall not be treated as a\nspeculative transaction. Further, an 'eligible transaction' for this purpose would be\none that

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

ACs., projectors, digital camera etc. and the assessee has claimed all these items as being installed as being used in the factory premises and since these assets qualified as machinery, we see no infirmity in the claim of the assessee for depreciation at the rate of 15% thereon treating these assets as plant & machinery. Argument of the ld.counsel

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

ACs., projectors, digital camera etc. and the assessee has claimed all these items as being installed as being used in the factory premises and since these assets qualified as machinery, we see no infirmity in the claim of the assessee for depreciation at the rate of 15% thereon treating these assets as plant & machinery. Argument of the ld.counsel

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

ITA 3218/AHD/2015[1993-94]Status: DisposedITAT Ahmedabad31 Dec 2024AY 1993-94

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mukesh R. Shah – Party in personFor Respondent: Shri Karun Kant Ojha, CIT-DR
Section 132Section 153Section 250

transferred to R.H.S. Family account No.681 in the same branch. An amount of Rs. 23,444/-was found to have been withdrawn in cash, the whereabouts of which were not known. iv) This information was elicited from the appellant himself in the shape of statement recorded on 24/4/1993 by the ITO, Ward -8(8), Ahmedabad which has been reproduced

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

ITA 3217/AHD/2015[1992-93]Status: DisposedITAT Ahmedabad31 Dec 2024AY 1992-93

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mukesh R. Shah – Party in personFor Respondent: Shri Karun Kant Ojha, CIT-DR
Section 132Section 153Section 250

transferred to R.H.S. Family account No.681 in the same branch. An amount of Rs. 23,444/-was found to have been withdrawn in cash, the whereabouts of which were not known. iv) This information was elicited from the appellant himself in the shape of statement recorded on 24/4/1993 by the ITO, Ward -8(8), Ahmedabad which has been reproduced