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43 results for “transfer pricing”+ Section 143clear

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Key Topics

Section 143(3)53Section 26347Addition to Income36Section 153(4)28Section 14824Section 10B14Section 8014Disallowance12Section 14711

SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA

In the result, the appeal is partly allowed

ITA 527/ASR/2024[2020-21]Status: DisposedITAT Amritsar28 Feb 2025AY 2020-21

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

For Appellant: S/Shri Sudhir SehgalFor Respondent: Shri K. Mehboob Ali Khan, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 80

Transfer Pricing Officer (in short ‘TPO’) dated 5.12.2021 for A.Y. 2020-21. 2. Brief facts of the case, as per the order/directions of the Dispute Resolution Panel-1, New Delhi [herein referred to as ‘DRP’ ] dated 24.06.2024 for A.Y. 2020-21 are as under:- “Profile of the Assessee: Satia Industries Limited (hereinafter referred as 'the Assessee

Showing 1–20 of 43 · Page 1 of 3

Section 80I11
Exemption8
Limitation/Time-bar8

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

ITA 477/ASR/2015[2008-09]Status: DisposedITAT Amritsar30 May 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

BRODAWAYS OVERSEAS LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALANDHAR

ITA 123/ASR/2018[2013-14]Status: DisposedITAT Amritsar30 May 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 48/ASR/2016[2010-11]Status: DisposedITAT Amritsar30 May 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 46/ASR/2016[2007-08]Status: DisposedITAT Amritsar30 May 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 49/ASR/2016[2011-12]Status: DisposedITAT Amritsar30 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

ITA 345/ASR/2016[2012-13]Status: DisposedITAT Amritsar30 May 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 47/ASR/2016[2009-10]Status: DisposedITAT Amritsar30 May 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

SHRI. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 40/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

143 or s. 144 has been used in contradistinction with reassessment under s. 147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed

SH. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PR. COMMISSIONER OF INCME TAX , BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 39/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

143 or s. 144 has been used in contradistinction with reassessment under s. 147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed

SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

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

ITA 702/ASR/2024[2021-22]Status: DisposedITAT Amritsar16 Dec 2025AY 2021-22

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 143(3)Section 144C(1)Section 144C(2)Section 144C(5)Section 80Section 80GSection 80ISection 92C

143(3) r.w.s. 144C(13)/144B of the income tax Act 61 (hereinafter the Act 61) dated 25/10/2024, in respect of which reference was made to TPO for determination of ALP u/s 92CA (after 2 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 necessary approval from PCIT), and assessment completed , considering transfer pricing adjustments ,vide order u/s 92CA(3) dated 30/10/2023

SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

ITA 250/ASR/2019[2011-12]Status: DisposedITAT Amritsar19 Oct 2022AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Sudhir Sehgal & Sh. P.N. Arora, AdvFor Respondent: Sh. Amlendu Nath Misra, CIT DR
Section 143(3)Section 263

section 263 cannot be taken into consideration and the Assessing Officer having taken a plausible view, the assessment as framed by the Assessing Officer cannot be considered to be erroneous and prejudicial to the interest of revenue. 8. Again, the Ld. Counsel, relied upon the judgment of Jurisdictional Bench of ITAT Amritsar Bench, Amritsar in the case of Sh. Jaswinder

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

143(1) Subsequently, Principal\nCommissioner invoked revision under section 263 on ground that a land was sold by\nassessee to an entity below value adopted by concerned authority for levy of stamp duty,\nand therefore, there was under-assessment of income to extent of differential amount, and\naccordingly, assessment made was contrary to provisions of section 50C as this aspect

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 18/ASR/2017[1987-88]Status: DisposedITAT Amritsar20 Dec 2022AY 1987-88

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 17/ASR/2017[1986-87]Status: DisposedITAT Amritsar20 Dec 2022AY 1986-87

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 16/ASR/2017[1985-86]Status: DisposedITAT Amritsar20 Dec 2022AY 1985-86

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 15/ASR/2017[1984-85]Status: DisposedITAT Amritsar20 Dec 2022AY 1984-85

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 22/ASR/2017[1991-92]Status: DisposedITAT Amritsar20 Dec 2022AY 1991-92

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 21/ASR/2017[1990-91]Status: DisposedITAT Amritsar20 Dec 2022AY 1990-91

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 19/ASR/2017[1988-89]Status: DisposedITAT Amritsar20 Dec 2022AY 1988-89

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing