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11 results for “transfer pricing”+ Section 153(3)(ii)clear

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Key Topics

Section 153(4)28Section 14820Section 143(3)17Addition to Income11Limitation/Time-bar8Section 686Section 1475Section 1324Long Term Capital Gains

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

In the result, the appeal of the assessee bearing ITA No

ITA 356/ASR/2017[2006-07]Status: DisposedITAT Amritsar13 Sept 2023AY 2006-07

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

Section 147Section 148Section 250

price of Rs.2,30,00,000/-, has wrongly been assessed and upheld in this case. I.T.A. No. 356/Asr/2017 3 Assessment Year: 2006-07 6. That the Id.CIT(A) was not justified in ignoring assessee's submissions that if at all the reopening was valid, the Id ITO could not have given a clean chit to other group of partners headed

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: Disposed
3
Section 2502
Section 250(6)2
House Property2
ITAT Amritsar
20 Dec 2022
AY 1987-88

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

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

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

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)

3) in view of explanation 1 (ii) of section 153. In this connection, it is submitted that the section 153 (2) stood as under as on 01/04/1994, the year in which the notice u/s 148 was issued: "[(2) No order of assessment, reassessment or re-computation shall be made under section 147 after the expiry of two years from

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

II, Bathinda Punjab 152123 [PAN: AAACN 7050J] (Respondent) (Appellant) Appellant by : Sh. Y. K. Sud & Sh. P. K. Anand, CAs : Sh. Charan Dass, Sr. D.R. Respondent by Date of Hearing : 15.07.2025 Date of Pronouncement : 26.09.2025 ORDER Per Udayan Dasgupta, J.M.: This appeal is filed by the assessee against the order of the ld. CIT(A) NFAC, Delhi dated 19.06.2023 passed

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

3. PCIT vs Swati Bajaj [2022] 139 taxmann.com 352 (Calcutta)/(2022) 288 Taxman 403 (Calcutta)/12022] 446 ITR 56 (Calcutta) (also discussed in above ITAT order) - Rejecting Tribunal holding that there is no merit in the argument of the revenue as the assessee has placed on record the relevant contract notes proper documentary evidence undertaking purchase/ sale of the shares

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

3. PCIT vs Swati Bajaj [2022] 139 taxmann.com 352 (Calcutta)/(2022) 288 Taxman 403 (Calcutta)/12022] 446 ITR 56 (Calcutta) (also discussed in above ITAT order) - Rejecting Tribunal holding that there is no merit in the argument of the revenue as the assessee has placed on record the relevant contract notes proper documentary evidence undertaking purchase/ sale of the shares