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7 results for “transfer pricing”+ Section 36(1)clear

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Key Topics

Section 14810Section 143(3)9Section 119Section 2(15)9Section 143(2)9Addition to Income7Section 1316Section 1474Section 12

M/S. GOVIND STONE PRIVATE LIMITED ,HAMIRPUR vs. INCOME TAX OFFICER -5(4), BANDA

ITA 258/ALLD/2018[2013-14]Status: DisposedITAT Allahabad19 Dec 2022AY 2013-14

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri. R. S. Agrawal, Adv. &VinayGoel, C.AFor Respondent: Shri A.K. Singh Sr.D.R
Section 143Section 143(2)Section 143(3)Section 56Section 68

price of Rs. 90/- per equity share comprising face value of Rs. 10 per equity share and share premium of Rs. 80 per equity share, aggregating to total amount raised to the tune of Rs. 1,53,00,000/- . The additions u/s 68 read with Section 158BBE is made wrt 168000 equity shares issued to 5 corporate entities, while additions

3
Exemption3
Capital Gains2
Long Term Capital Gains2

SHOBHA RASTOGI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, ALLAHABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 47/ALLD/2020[2008-09]Status: DisposedITAT Allahabad13 Aug 2021AY 2008-09

Bench: Shri.Vijay Pal Raoassessment Year: 2008-09 Smt. Shobha Rastogi, V. Deputy Commissioner Of Income 30-A, M.G. Marg, Civil Lines, Tax, Circle-1, Allahabad, U.P. Allahabad, U.P. Pan-Afqpr4774R (Appellant) (Respondent) Appellant By: Mr. Praveen Godbole, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 12.08.2021 Date Of Pronouncement: 13.08.2021

For Appellant: Mr. Praveen Godbole, C.AFor Respondent: Mr. A.K. Singh, Sr. DR
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 50C

36,266/- and a long term capital loss of Rs. 2,97,227/- was declared. But on the perusal of the sale deeds (two separately, for commercial and for residential property respectively), it was seen that the sales were made for a total consideration of Rs, 42,00,000/- (25,00,000+17,000,000), but the valuation

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 87/ALLD/2020[2014-15]Status: DisposedITAT Allahabad31 Jan 2025AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

36,145/- under the various funds & grants received which had not been routed through the Income and Expenditure Account and could not have been added to the surplus as per Income and Expenditure Account as the appellant did not have any right, title or interest of its own in the said sum and the same had not accrued

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 88/ALLD/2020[2015-16]Status: DisposedITAT Allahabad31 Jan 2025AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

36,145/- under the various funds & grants received which had not been routed through the Income and Expenditure Account and could not have been added to the surplus as per Income and Expenditure Account as the appellant did not have any right, title or interest of its own in the said sum and the same had not accrued

ALLAHABAD DEVELOPMENT AUTHORITY,ALLAHABAD vs. ACIT (EXEMPTION), LUCKNOW

In the result all three appeals of the Assessee are partly allowed

ITA 89/ALLD/2020[2016-17]Status: DisposedITAT Allahabad31 Jan 2025AY 2016-17

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Ashish Bansal, AdvocateFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 11Section 12Section 143(3)Section 2(15)Section 260A

36,145/- under the various funds & grants received which had not been routed through the Income and Expenditure Account and could not have been added to the surplus as per Income and Expenditure Account as the appellant did not have any right, title or interest of its own in the said sum and the same had not accrued

GIRDHAR GOPAL RASTOGI,MIRZAPUR vs. I.T.O. WARD 3(1), MIRZAPUR

In the result, the additional ground of the appeal of the assessee is allowed

ITA 162/ALLD/2019[2012-13]Status: DisposedITAT Allahabad13 May 2022AY 2012-13

Bench: Shri.Vijay Pal Raoassessment Year: 2012-13 Sri Girdhar Gopal Rastogi, V. Commissioner Of Income Tax Dhundi Katra, Mirzapur, U.P. (Appeal), Allahabad Pan-Aanpr8525N (Appellant) (Respondent) Appellant By: Mr. R.N. Yadav, Adv & Mr. R.K. Kalyani, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 26.04.2022 Date Of Pronouncement: 13.05.2022

For Appellant: Mr. R.N. Yadav, Adv & Mr. R.KFor Respondent: Mr. A.K. Singh, Sr. DR
Section 131Section 133ASection 254(2)

transfer pricing in excess of Rs. 10 Crores or more which is confirmed in appeal or is pending before an appellate authority. c) Cases involving addition in an earlier assessment year in excess of Rs. 10 lacs on a substantial and recurring question of law or fact which is confirmed in appeal or is pending before an appellate authority

SANJAY MAJUMDAR,ALLAHABAD vs. PR. CIT, ALLAHABAD

ITA 68/ALLD/2018[2012-13]Status: DisposedITAT Allahabad28 Jan 2021AY 2012-13

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2012-13 Mr. Sanjay Majumdar, V. The Principal Commissioner Type Ii – 112, Devprayagam Of Income Tax, Sangam Vatika – Jhalwa, Aayakar Bhawan, Allahabad 211012 38, M.G. Marg, Civil Lines, Allahabad 211001 Pan: Adopm 2688P (Appellant) (Respondent)

For Appellant: Shri Basudev Banerjee, CAFor Respondent: Shri Debashish Chanda, CIT-DR
Section 147Section 154Section 263

36,84,950/-, vide reassessment order dated 24.06.2016 , which reassessment order was later 2 Assessment Year: 2012-13 Sanjay Majumdar rectified under the provisions of Section 154 of the 1961 Act , dated 27.02.2017 as mistake apparent from records had crept in the aforesaid reassessment order, and income of the assessee was computed at Rs. 43,55,960/- by rectifying