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120 results for “transfer pricing”+ Undisclosed Incomeclear

Sorted by relevance

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Key Topics

Addition to Income77Section 143(3)60Section 153A40Section 14835Section 6835Disallowance30Section 14726Section 153C24Survey u/s 133A

SUN PHARMACEUTICALS INDUSTRIES LTD.,,BARODA vs. THE ACIT, CENTRAL CIRCLE-1, BARODA

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

ITA 1659/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad20 Jun 2019AY 2008-09

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. आयकर अपील सं./Ita No.1659/Ahd/2015 2. आयकर अपील सं./Ita No.1689/Ahd/2015 ("नधा"रण वष"/Assessment Year : 2008-09 ) बनाम/ 1. Sun Pharmaceuticals 1. The Acit Industries Ltd. Cen.Cir-1 Vs. “Sparc” Tandalja Baroda – 20 2. The Acit 2. Sun Pharmaceu- Central Circle-1 Ticals Industries Baroda Ltd. Baroda. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcs 3124K (अपीलाथ"/Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से/ Appellant By : Shri S.N. Soparkar, Ar ""यथ" क" ओर से/Respondent By: Shri R.C. Panday, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing 28/03/2019 घोषणा क" तार"ख /Date Of Pronouncement 20/06/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Cross-Appeals Have Been Filed At The Instance Of The Assessee & Revenue Against The Order Of The Commissioner Of Income Tax (Appeals)–2, Vadodara [Cit(A) In Short] Vide Appeal No.Cab/(A)- 2/387/2014-15 Dated 31/03/2015 Arising In The Assessment Order Passed Under S.143(3) R.W.S.147 Of The Income Tax Act, 1961(Hereinafter Referred To As "The Act") Dated 14/02/2014 Relevant To Assessment Year (Ay) 2008-09. Ita Nos.1659/Ahd/2015 (By Assessee) & Ita No.1689/Ahd/2015 (By Revenue) Sun Pharmaceuticals Industries Ltd. Vs. Acit Asst.Year - 2008-09 2

For Appellant: Shri S.N. Soparkar, ARFor Respondent: Shri R.C. Panday, CIT-DR
Section 143(3)Section 147Section 148

Showing 1–20 of 120 · Page 1 of 6

23
Section 10(38)20
Section 13220
Penalty18
Section 40A(2)(b)

transfer of the know-how for manufacturing of the same to UTL by SPIL, SPIL has agreed to charge the price being estimated cost of carrying out such research and development activities as increased by the margin not exceeding 15% of such estimated cost which would be mutually agreed upon by both the parties from time to time." [Emphasis supplied

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 217/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 212/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2006-07

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 213/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2007-08

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 210/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 211/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2005-06

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 218/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 214/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2008-09

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 216/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

ITA 215/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI PRAHLAD S. MEHTA L/H OF LATE RAJPAL P. MEHTA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(3) NOW WARD-5(2)(3), AHMEDABAD

In the result, this ground of appeal is dismissed

ITA 796/AHD/2016[2004-05]Status: DisposedITAT Ahmedabad16 Nov 2017AY 2004-05
For Appellant: Ms Urvashi Shodhan, A.RFor Respondent: Shri G.C. Daxini, Sr. D.R
Section 147Section 148Section 234BSection 271Section 271(1)(c)

price of these shares Rs.5,59,500/- is added as income from undisclosed sources, therefore, Rs.5,33,747/- is requested to be reduced from income of appellant if addition of Rs.5,59,500/- is sustained or else there shall be double taxation of income.” I.T.A Nos. 796 & 797/Ahd/2016 A.Y. 2004-05 Page No 6 Prahlad S. Mehta & Najuben Rajpal Mehta

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-3(3),, AHMEDABAD vs. M/S. ATRI DEVELOPERS,, AHMEDABAD

Appeal is dismissed

ITA 2855/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

transferred by the society to the Appellant - Clause 29 it is mentioned that the landowner will give the Appellant 20% as development charge Reading of the above clauses, makes it amply clear that the expenses towards the development was required to be borne and incurred by the society, whereas the role of the appellant was only towards arranging such materials

M/S. ATRI DEVELOPERS,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(3),, AHMEDABAD

Appeal is dismissed

ITA 2859/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

transferred by the society to the Appellant - Clause 29 it is mentioned that the landowner will give the Appellant 20% as development charge Reading of the above clauses, makes it amply clear that the expenses towards the development was required to be borne and incurred by the society, whereas the role of the appellant was only towards arranging such materials

THE DCIT, CIRCLE-8,, AHMEDABAD vs. SAMBHAV INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result, appeal of the Revenue is allowed

ITA 1818/AHD/2015[2012-13]Status: DisposedITAT Ahmedabad05 Jan 2022AY 2012-13

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1818/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2012-13 Dcit, Cir.4(1)(1) Vs. Sambhav Infrastructure P.Ltd. Ahmedabad. B-12, Amar Aprtment Vasna Barrage Road Vasna, Ahmedabad. Pan : Aakcs 5194 C

For Appellant: NoneFor Respondent: Shri Mohd Usman,CIT-DR
Section 133ASection 143(2)

price increase in the construction material, profit out of such extra work, was almost nil. However, in order to buy peace, an amount of Rs.4 crores on such extra collection as profit in the return. Assessee has relied upon certain decision of higher authorities for the proposition of law that entire admitted undisclosed income could not be taxed, and only

MANISH DEVENDRAKUMAR SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

The appeal of the assessee is allowed in full

ITA 918/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad25 Feb 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.918/Ahd/2024 िनधा"रण वष" /Assessment Year : 2014-15 Manish Devendrakumar Shah The Ito बनाम/ 206, 2Nd Floor, Kalash 1 Ward-5(3)(1) V/S. Navrangpura Ahmedabad Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aqjps 4226 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Divatia, Ar & Shri Samir Vora, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20 /02/2025 घोषणा की तारीख /Date Of Pronouncement: 25/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri S.N. Divatia, AR &For Respondent: Shri Rignesh Das, Sr.DR
Section 10(38)Section 143(1)Section 147Section 250Section 68

undisclosed income though the purchase price of RS. 250000/- was paid by cheque from regular bank a/c. It is therefore prayed that the addition of Rs. 1,07,92,400/-/- u/s 68 of Act confirmed by the CIT(A) should be deleted. 5. During the course of hearing before us, the Authorized Representative (AR) of the assessee preferred

SHRI PRAVINCHANDRA R PATEL,VADODARA vs. DCIT, CENTRAL CIRCLE-2, VADODARA

ITA 299/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad13 Jan 2022AY 2015-16
Section 143(3)Section 147Section 69BSection 69C

price. Similarly, the contention of the assessee that cash of Rs. 2.98 crores was paid out of undisclosed income of the directorsof Rs. 3.21 crores is not accepted for the reason that there was no evidence that the disclosure was made against unaccounted investment. The return was filed by the directors and their relatives under section 139(4) disclosing brokerage

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

ITA 194/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad13 Jan 2022AY 2014-15
Section 143(3)Section 147Section 69BSection 69C

price. Similarly, the contention of the assessee that cash of Rs. 2.98 crores was paid out of undisclosed income of the directorsof Rs. 3.21 crores is not accepted for the reason that there was no evidence that the disclosure was made against unaccounted investment. The return was filed by the directors and their relatives under section 139(4) disclosing brokerage

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

ITA 195/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad13 Jan 2022AY 2015-16
Section 143(3)Section 147Section 69BSection 69C

price. Similarly, the contention of the assessee that cash of Rs. 2.98 crores was paid out of undisclosed income of the directorsof Rs. 3.21 crores is not accepted for the reason that there was no evidence that the disclosure was made against unaccounted investment. The return was filed by the directors and their relatives under section 139(4) disclosing brokerage

THE ITO, WARD-9(1),, AHMEDABAD vs. SHRI RASIKBHAI AMBALAL PATEL,HUF, AHMEDABAD

In the result, appeal of the revenue is dismissed

ITA 1308/AHD/2013[2009-10]Status: DisposedITAT Ahmedabad13 Feb 2018AY 2009-10

Bench: Shri S.S. Godara & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. No.1308/Ahd/2013 ("नधा"रण वष" / Assessment Year : 2009-10)

For Appellant: Shri V.K. Singh, Sr.DRFor Respondent: Shri Dipak Shah, AR

undisclosed business income. It was contended by the AO that the assessee has executed sale deed with the purchaser and also has given possession of the property coupled with the fact that major sale consideration has been received during the year under consideration. The AO accordingly contended that the assessee has completed the performance of contract as per Transfer

NARAYANBHAI SHIVABHAI PATEL,MEHSANA vs. THE ITO, WARD-1, MEHSANA

In the result, the appeal of the assessee is allowed

ITA 1357/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 143(3)Section 270ASection 270A(6)Section 270A(6)(a)Section 270A(6)(b)Section 56(2)(x)

income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed