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17 results for “transfer pricing”+ Section 234Dclear

Sorted by relevance

Mumbai136Delhi100Bangalore18Raipur17Ahmedabad17Hyderabad11Cochin6Kolkata4Indore3Surat3Jodhpur2Guwahati2Jaipur2Pune2Ranchi1Visakhapatnam1

Key Topics

Section 14715Section 234B11Section 153C10Section 80I9Section 92C8Set Off of Losses8Addition to Income8Section 143(3)7Penalty

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

Transfer pricing adjustment on account Rs. 10,29,60,436/- of corporate guarantee (as per Para No. 11) 2. TP adjustments on account of interest Rs. 8,78,43,328/- convertible loans (as per Para No. 12) 3. TP adjustments on account of reimbursement Rs 10,63,95,565/- of expenses ( as per Para No. 13) 4. TP adjustments

7
Section 139(1)6
Reopening of Assessment6
Survey u/s 133A6

BUNDY INDIA LTD.,,BARODA vs. THE DCIT, CIRCLE-1(1),, BARODA

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

ITA 1764/AHD/2013[2007-08]Status: DisposedITAT Ahmedabad10 Jun 2024AY 2007-08

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri Parin Shah, A.RFor Respondent: Date of Hearing
Section 143(3)Section 92CSection 92C(3)

transfer pricing study in not submitted by the appellant. 6.3 The AO/CIT(A) erred in law and on facts, in disregarding aggregation of management fees with the manufacturing segment as adopted by the appellant for benchmarking the international transactions. 6.4 The AO/CIT(A) erred in law and on facts, in holding that benefit received by the appellant on paying management

BOCK COMPRESSORS INDIA PRIVATE,BENGALURU vs. THE DY. CIT, CIRCLE - 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed

ITA 1484/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad09 May 2025AY 2020-21

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2020-21

For Appellant: Shri Ketan Ves, A.R. &For Respondent: Shri Uday Kakne, Sr. D.R
Section 143(3)Section 144(5)Section 144CSection 234BSection 253Section 270ASection 920Section 92ASection 92C

Transfer Pricing Study Report using Resale Price Method (RPM) accordance with Section 920 and Section 920 of the Act read with Rule 10B, 10C and 10D of the Income-tax Rules, 1962 (the “Rules”) without providing the cogent reason. 3. The ld. AO., Ld. TPO and Ld. DRP erred in law and on facts in not appreciating that goods sold

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 244/AHD/2022[2019-20]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

price (ALP) of the international transaction as Nil. 7.1 The Ld. AO/TPO endorsed that the PSC is a self-serving document but erred in not allowing the expenses which were restricted in PSC to 1% of the total contract cost on the ground that cost benefit analysis was not done. It is submitted that prescribing 1% of contract cost

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

price (ALP) of the international transaction as Nil. 7.1 The Ld. AO/TPO endorsed that the PSC is a self-serving document but erred in not allowing the expenses which were restricted in PSC to 1% of the total contract cost on the ground that cost benefit analysis was not done. It is submitted that prescribing 1% of contract cost

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 80/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

price (ALP) of the international transaction as Nil. 7.1 The Ld. AO/TPO endorsed that the PSC is a self-serving document but erred in not allowing the expenses which were restricted in PSC to 1% of the total contract cost on the ground that cost benefit analysis was not done. It is submitted that prescribing 1% of contract cost

PUNEET SINGH R. BHADOURIA,VADODARA vs. THE ITO, WARD-4(1)(9), VADODARA

In the result, appeal of the assessee is partly allowed

ITA 334/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad17 Jan 2024AY 2014-15

Bench: Ms. Suchitra Kambleassessment Year: 2014-15

Section 10(38)Section 139(1)Section 142(1)Section 143(2)Section 148Section 234ASection 271(1)(c)Section 69Section 69ASection 69C

234D is not justified. 7. Initiation of penalty under Section 271(1)(c) is not justified.” 3. The assessee filed return of income on 14.11.2014 declaring total income at Rs.1,49,070/-. Notice under Section 148 of the Income Tax Act, 1961 was issued on 26.03.2019. Notice under Section 142(1) alongwith Questionnaire was issued on 14.06.2019. In response

JET AIR AGENCIES PVT LTD,WEST BENGAL vs. CENTRAL CIRCLE 2(3)AHMEDABAD, AHMEDABAD

In the result, Ground Nos

ITA 685/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1594/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad31 May 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1595/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1596/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

ITA 1597/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty