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17 results for “transfer pricing”+ Section 234Aclear

Sorted by relevance

Delhi234Mumbai151Bangalore71Jaipur31Ahmedabad17Agra14Hyderabad13Pune12Kolkata7Chennai6Lucknow6Nagpur5Indore4Jodhpur3Surat3Chandigarh2Visakhapatnam1Amritsar1Rajkot1Ranchi1Cochin1

Key Topics

Section 3727Section 153C10Double Taxation/DTAA10Section 234B9Section 90(2)9Section 234A9Section 2349Section 271(1)(c)9Penalty9Disallowance

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)

234A of the Act. 12. On the facts and circumstances of the case and in law, the Ld. AO erred in computing an interest of INR 23,048 under section 234C of the Act. The Appellant prays that the Ld. AO be directed to delete the interest of INR 23,048 computed under section 234C

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

ITA 466/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2016-17
9
Limitation/Time-bar9
Section 1476
Section 115
Section 143(3)
Section 234B
Section 92C

Transfer Pricing Officer for determining Arms’ Length Price of the International Transaction undertaken by the assessee company and the TPO accepted the price at which International Transaction were recorded and no adverse inference was drawn by passing order dated 28-10-2019 under section 92CA(3) of the Act. Following the same, the Ld AO accepted the returned income filed

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

Section 147 of the Act were held by us to be bad in law. 25. In the result, the appeal of the assessee is partly allowed in ITA No. 249/Ahd/2023 for A.Y. 2016-17. Assessment Year 2016-17 (Department’s Appeal) (ITA No. 325/Ahd/2023) 26. The Department has taken the following grounds of appeal: “1. In the facts

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

Section 147 of the Act were held by us to be bad in law. 25. In the result, the appeal of the assessee is partly allowed in ITA No. 249/Ahd/2023 for A.Y. 2016-17. Assessment Year 2016-17 (Department’s Appeal) (ITA No. 325/Ahd/2023) 26. The Department has taken the following grounds of appeal: “1. In the facts

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

Section 147 of the Act were held by us to be bad in law. 25. In the result, the appeal of the assessee is partly allowed in ITA No. 249/Ahd/2023 for A.Y. 2016-17. Assessment Year 2016-17 (Department’s Appeal) (ITA No. 325/Ahd/2023) 26. The Department has taken the following grounds of appeal: “1. In the facts

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

Section 147 of the Act were held by us to be bad in law. 25. In the result, the appeal of the assessee is partly allowed in ITA No. 249/Ahd/2023 for A.Y. 2016-17. Assessment Year 2016-17 (Department’s Appeal) (ITA No. 325/Ahd/2023) 26. The Department has taken the following grounds of appeal: “1. In the facts

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

Section 147 of the Act were held by us to be bad in law. 25. In the result, the appeal of the assessee is partly allowed in ITA No. 249/Ahd/2023 for A.Y. 2016-17. Assessment Year 2016-17 (Department’s Appeal) (ITA No. 325/Ahd/2023) 26. The Department has taken the following grounds of appeal: “1. In the facts

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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 149/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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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 150/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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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 148/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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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)

Transfer Pricing Adjustment in 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 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

BHAVNA SHETALKUMAR PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee stands allowed

ITA 1103/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2016-17
For Appellant: \nShri Parin S Shah, ARFor Respondent: \nShri Santosh Kumar, Sr. DR
Section 10(38)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 68

234A, 234B and 234C is unjustified.\n11.\nThe assessee also filed following additional grounds of appeal:\n1. The order passed by AO is required to be quashed as AO proceeded with\nassessment without issuance of notice u/s 143(2) of the Act which is mandatory\nrequirements.\n12.\nOn the additional ground relating to the alleged non issuance of\nnotice under