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12 results for “transfer pricing”+ Section 172(4)clear

Sorted by relevance

Mumbai239Delhi131Hyderabad72Chennai65Cochin61Chandigarh59Jaipur48Bangalore45Raipur19Surat14Ahmedabad12Nagpur10Indore10Agra8Kolkata7Varanasi5Lucknow4Rajkot4Cuttack3Pune2Jodhpur2Dehradun1Allahabad1Guwahati1

Key Topics

Section 26318Addition to Income10Section 153C7Section 143(3)6Section 805Section 80I4Section 2504Deduction4Section 353

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)

4. In respect of the transfer pricing adjustment, the assessee filed objections before the Dispute Resolution Panel against the draft order. The DRP, after detailed consideration, rejected the objections specifically those relating to application of turnover filter, functional comparability of selected companies, and claim for risk or economic adjustments. The DRP upheld the findings of the TPO in entirety

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 Ahmedabad
Section 1323
Search & Seizure3
Revision u/s 2633
29 Jan 2026
AY 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)

Transfer Pricing Officer (TPO) had proposed an adjustment of Rs.38,54,947/-, rejecting 4 comparables selected by the assessee in its benchmarking exercise. The Dispute Resolution Panel (DRP) additionally rejected four more comparables finding them to be functionally not comparable to the tested party and directed that the adjustment be made to impugned International transaction to the tune of Rs.98

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

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

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

Pricing and also much lesser than the prevailing interest rates in the market. It is undisputed fact that based on contractual obligation the late payment of 232 days has attracted the penal interest of Rs.50,16,000/- which is to be allowed u/s.37(1) of the Act. Thus the addition made by the Ld AO on this account is against

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

ITA 741/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

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

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

Pricing and also much lesser than the prevailing interest rates in the market. It is undisputed fact that based on contractual obligation the late payment of 232 days has attracted the penal interest of Rs.50,16,000/- which is to be allowed u/s.37(1) of the Act. Thus the addition made by the Ld AO on this account is against

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 443/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 442/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 447/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 448/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

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

4 days for which interest shall ITA.Nos.2365/Ahd/2018&5 others A.Y.2013-14 44 be charged and the same has already been made subject to the addition in the AY 2012-13 by the order of the ld. predecessor CIT(A). Hence the learned CIT(A) deleted the addition of interest charged by the TPO/AO for Rs. 14,53,190/- 56.2 Likewise

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

ITA 1052/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

price of Rs.18.11 crores. Shri Suresh R Thakkar had confirmed that these seized documents were in respect of sale of land by Rajeshbhai Brahmbhatt and Arunaben K Zhaveri to one Shri N. K. Patel of Sun Builder Group. He had also stated that cash and cheque payments were involved in this transaction and that the deal was facilitated through

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

ITA 1053/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

price of Rs.18.11 crores. Shri Suresh R Thakkar had confirmed that these seized documents were in respect of sale of land by Rajeshbhai Brahmbhatt and Arunaben K Zhaveri to one Shri N. K. Patel of Sun Builder Group. He had also stated that cash and cheque payments were involved in this transaction and that the deal was facilitated through

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

ITA 1054/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad20 Jan 2026AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

For Appellant: Shri M K Patel, with Shri Vartik Choksi, ARsFor Respondent: Shri Sher Singh, CIT.DR
Section 132Section 143(3)Section 153CSection 263

price of Rs.18.11 crores. Shri Suresh R Thakkar had confirmed that these seized documents were in respect of sale of land by Rajeshbhai Brahmbhatt and Arunaben K Zhaveri to one Shri N. K. Patel of Sun Builder Group. He had also stated that cash and cheque payments were involved in this transaction and that the deal was facilitated through