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38 results for “transfer pricing”+ Carry Forward of Lossesclear

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Key Topics

Section 733Section 433Section 260A2Section 14A2Deduction2

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD

ITAT/89/2025HC Calcutta21 Jul 2025

Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :

For Appellant: Mr. Prithu Dudhoria, AdvocateFor Respondent: Mr. J.P. Khaitan, Senior Advocate
Section 14ASection 260ASection 37(1)Section 40a

carried out certain international transactions within the meaning of Section 92B of the Act with associated enterprises. The said international transactions were referred to Transfer Pricing Officer (TPO) for determination of Arm's Length Price and adjustment, if any, and by order dated 30.01.2024, TPO did not make any transfer pricing adjustment. Thereafter the assessing officer called for various details

Showing 1–20 of 38 · Page 1 of 2

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. SAJJADBHAI NURUDDIN NANDARBARWAL

ITAT/129/2021HC Calcutta14 Jun 2022

Bench: :

transferring, alienating and/or creating any third party interest in respect of the properties mentioned in annexure "M" in GA No. 725 of 2019 and Annexure "R" in GA No. 733 of 2019 respectively was vacated. The interim order was vacated at the final hearing of the injunction application by a subsequent bench on the ground that the claim

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. SUMAN KUMAR

ITAT/128/2021HC Calcutta14 Jun 2022

Bench: :

transferring, alienating and/or creating any third party interest in respect of the properties mentioned in annexure "M" in GA No. 725 of 2019 and Annexure "R" in GA No. 733 of 2019 respectively was vacated. The interim order was vacated at the final hearing of the injunction application by a subsequent bench on the ground that the claim

THE COMMISSIONER OF INCOME TAX, KOLKATA -II, KOLKATA vs. M/S. MADANLAL LIMITED

ITA/51/2013HC Calcutta28 Jul 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 28Th July, 2025. Appearance : Mr. Aryak Dutt, Adv. Mr. Prithu Dudhoria, Adv. …For Appellant.

Section 260ASection 28Section 43Section 43(5)Section 73Section 73(4)

transfer of the commodity or scrips: Provided that for the purposes of this clause- 4 (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-1, KOLKATA vs. KRISHNA KUMAR PARSURAMKA

In the result, these appeals are allowed and the substantial

ITAT/130/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. PRAKASHO DEVI SARIA

In the result, these appeals are allowed and the substantial

ITAT/138/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX ,BURDWAN vs. BIJAYA TAH

In the result, these appeals are allowed and the substantial

ITAT/122/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-12, KOLKATA vs. MUKTA AGARWAL

In the result, these appeals are allowed and the substantial

ITAT/44/2020HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX vs. MUKESH SARAOGI (HUF)

In the result, these appeals are allowed and the substantial

ITAT/76/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX -5,KOLKATA vs. SWATI BAJAJ

In the result, these appeals are allowed and the substantial

ITAT/6/2022HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. POOJA JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

ITAT/87/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-9, KOLKATA vs. GITESH TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/154/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX 9, KOLKATA vs. PUSPA DEVI TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/150/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-SILIGURI vs. SHEKHAR AGARWAL

In the result, these appeals are allowed and the substantial

ITAT/139/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PR CIT 9, KOLKATA vs. MANISHA TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/155/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. JEMISH SHAH

In the result, these appeals are allowed and the substantial

ITAT/57/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. SRI SATYA NARAYAN SARIA

In the result, these appeals are allowed and the substantial

ITAT/168/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. SHRI MAHENDRA KUMAR PERIWAL

In the result, these appeals are allowed and the substantial

ITAT/136/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAJESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

ITAT/26/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made

PRINCIPAL COMMISSIONER OF INCOME TAX vs. NAND KISHORE AGARWALA

In the result, these appeals are allowed and the substantial

ITAT/22/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

carried out by either of the concerned persons directly related to the equity shares of the said company in which the assessee had traded. Further the assessee would state that any general information relating to other company’s shares cannot be the basis for casting allegations of suspicion and treating a transaction in-genuine, as no addition can be made