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60 results for “transfer pricing”+ Section 160clear

Sorted by relevance

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Key Topics

Section 143(3)64Section 14A46Disallowance41Addition to Income39Section 271A38Section 92C28Section 3727Section 153A26Section 263

ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

ITA 359/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2018-19

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

Section 92C(1)

160/-, which was later revised on 29/03/2019 at Rs.70,15,57,590/-. During the year under consideration, the assessee had entered into international transactions which were reported in Form 3CEB. The matter was referred to the Transfer Pricing Officer who, after examining the transactions, held that the profit level indicator of the assessee was not within the arm’s length

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 319/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad

Showing 1–20 of 60 · Page 1 of 3

23
Penalty21
Depreciation19
Section 27115
21 Jan 2025
AY 2014-15

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein deleted the levy of penalty u/s. 271AA of the Act as follows:- "Section 92D, read with sections 271AA and 271G, of the Income- tax Act, 1961 Transfer Pricing

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 324/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2019-20

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein deleted the levy of penalty u/s. 271AA of the Act as follows:- "Section 92D, read with sections 271AA and 271G, of the Income- tax Act, 1961 Transfer Pricing

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 322/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein deleted the levy of penalty u/s. 271AA of the Act as follows:- "Section 92D, read with sections 271AA and 271G, of the Income- tax Act, 1961 Transfer Pricing

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 321/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein deleted the levy of penalty u/s. 271AA of the Act as follows:- "Section 92D, read with sections 271AA and 271G, of the Income- tax Act, 1961 Transfer Pricing

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 323/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2018-19

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein deleted the levy of penalty u/s. 271AA of the Act as follows:- "Section 92D, read with sections 271AA and 271G, of the Income- tax Act, 1961 Transfer Pricing

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 320/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2015-16

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein it is held as under:\n5.5 On perusal of the Transfer Pricing Order, it is apparent that -\n(i) the TPO has not made any adjustments relating to vessel\npurchase transaction with AE\n(ii) there is no whisper in entire transfer pricing order that\nappellant has failed to maintain documents specified in Section

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 318/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2013-14

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

160 wherein it is held as under:\n\n5.5 On perusal of the Transfer Pricing Order, it is apparent that -\n\n(i) the TPO has not made any adjustments relating to vessel\npurchase transaction with AE\n(ii) there is no whisper in entire transfer pricing order that\nappellant has failed to maintain documents specified in Section

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

160 taxmann.com 604 (Guwahati – Tribunal), the ITAT held that a partnership firm being a separate assessable “person” under the Income Tax Act, would not be entitled to same exemption under Section 10(26) of the Act as any or all of individual partners would be in their individual capacity. The Larger Bench of the Tribunal made the following observations

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

160 taxmann.com 604 (Guwahati – Tribunal), the ITAT held that a partnership firm being a separate assessable “person” under the Income Tax Act, would not be entitled to same exemption under Section 10(26) of the Act as any or all of individual partners would be in their individual capacity. The Larger Bench of the Tribunal made the following observations

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

160 taxmann.com 604 (Guwahati – Tribunal), the ITAT held that a partnership firm being a separate assessable “person” under the Income Tax Act, would not be entitled to same exemption under Section 10(26) of the Act as any or all of individual partners would be in their individual capacity. The Larger Bench of the Tribunal made the following observations

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

160 taxmann.com 604 (Guwahati – Tribunal), the ITAT held that a partnership firm being a separate assessable “person” under the Income Tax Act, would not be entitled to same exemption under Section 10(26) of the Act as any or all of individual partners would be in their individual capacity. The Larger Bench of the Tribunal made the following observations

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

160 taxmann.com 604 (Guwahati – Tribunal), the ITAT held that a partnership firm being a separate assessable “person” under the Income Tax Act, would not be entitled to same exemption under Section 10(26) of the Act as any or all of individual partners would be in their individual capacity. The Larger Bench of the Tribunal made the following observations

M/S. GUJARAT AMBUJA EXPORTS LTD.,,AHMEDABAD vs. THE PR. CIT-1, AHMEDABAD

In the result the order of the Ld

ITA 194/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad26 Sept 2025AY 2017-18

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

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Alpesh Parmar, CIT.DR
Section 143(3)Section 144C(3)Section 263Section 32ASection 35ASection 40A(3)

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— ITA No. 194/Ahd/2022 [ M/s. Gujarat Ambuja Exports Ltd. vs. Pr.CIT

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour

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)

160/- is directed to be deleted. Ground of appeal 1 to 5 is allowed.” ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 18. In our considered view this issue is squarely covered in favour