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8 results for “transfer pricing”+ Section 2(71)clear

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Key Topics

Section 26321Section 143(3)11Section 699Addition to Income6Section 132(4)4Section 1482Bogus/Accommodation Entry2Bogus Purchases2

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

ITA 121/ASR/2020[2015-16]Status: DisposedITAT Amritsar31 Mar 2021AY 2015-16
For Appellant: Shri Deepak ChopraFor Respondent: Smt.Prabhjot Kaur, CIT
Section 143(3)Section 263

transfer of fund abroad The Assessing Officer has also failed to examine the authenticity of purchase of 2323 shares ON 31-03-2014 for Rs. 7,23,34,900/- which have been sold for Rs.20,41,087/- after a very short period. It is of importance that the shares are unquoted shares and the basis of valuation of unquoted share

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: Disposed
ITAT Amritsar
13 Sept 2023
AY 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

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

71 Taxmann.com 273, wherein the order u/s 263 was set aside, since the Ld. Assessing Officer had examined the issue in depth and that judgment has been upheld by the Hon’ble Apex Court in a decision, reported in 77 Taxmann.com 15 and it was held that, where the view has been taken by the Assessing Officer, after making proper/requisite

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 673/ASR/2014[2011-12]Status: DisposedITAT Amritsar22 Mar 2023AY 2011-12

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

71 (SC). We are of the view that unless there is evidence that more than what is stated in the documents or was received, no higher price can be taken to be the basis for computation of tax either in business transaction or capital gain transactions. The entire onus is on Revenue and the inferences might be drawn in certain

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 672/ASR/2014[201-11]Status: DisposedITAT Amritsar22 Mar 2023

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

71 (SC). We are of the view that unless there is evidence that more than what is stated in the documents or was received, no higher price can be taken to be the basis for computation of tax either in business transaction or capital gain transactions. The entire onus is on Revenue and the inferences might be drawn in certain

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 671/ASR/2014[2009-10]Status: DisposedITAT Amritsar22 Mar 2023AY 2009-10

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

71 (SC). We are of the view that unless there is evidence that more than what is stated in the documents or was received, no higher price can be taken to be the basis for computation of tax either in business transaction or capital gain transactions. The entire onus is on Revenue and the inferences might be drawn in certain

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 44/ASR/2021[2012-13]Status: DisposedITAT Amritsar15 Nov 2022AY 2012-13

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

71,702/- 2010-11 Khushi Agro Total 1,65,77,133/- There is another information that the assessee company has received Rs. 86,25,29,622/ - against the export of rice (sales) during the F. Y 2010-11 from M/s Gautam General Trading LLC based in Dubai (U.A.E) which is owned by Sh. Sanjiv Aggarwal & his son Sh. Gautam Aggarwal

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 45/ASR/2021[2014-15]Status: DisposedITAT Amritsar15 Nov 2022AY 2014-15

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

71,702/- 2010-11 Khushi Agro Total 1,65,77,133/- There is another information that the assessee company has received Rs. 86,25,29,622/ - against the export of rice (sales) during the F. Y 2010-11 from M/s Gautam General Trading LLC based in Dubai (U.A.E) which is owned by Sh. Sanjiv Aggarwal & his son Sh. Gautam Aggarwal