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4 results for “penalty u/s 271”+ TP Methodclear

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Delhi452Mumbai232Bangalore136Pune42Ahmedabad41Kolkata39Indore25Hyderabad19Chennai16Jaipur11Surat7Chandigarh4Visakhapatnam4Dehradun2Karnataka1

Key Topics

Transfer Pricing4Addition to Income4Section 1443TP Method3Section 802

M/S NECTAR LIFESCIENCE LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

ITA 1497/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh17 Feb 2022AY 2015-16
For Appellant: Shri Yogesh Monga, CAFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 144C(13)Section 144C(5)Section 271Section 80

penalty proceedings u/s 271(l)(c) of the Income Tax Act 1961 despite the fact that complete information was disclosed and nothing was concealed. 5. The assessee craves leave to alter, amend or withdraw all or any of the objections herein or at any further grounds as may be considered necessary and to submit such statement/documents and papers

M/S DSM SINOCHEM PHARMACEUTICALS INDIA PVT. LTD. ,TOANSA vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is partly allowed

ITA 1592/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh20 Jan 2022AY 2014-15

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018(िन.व.2014-15) ITA NO.253/Chd./2026 (A.Y.2011-12) ITA NO.1592/Chd./2018 (A.Y.2014-15) payment in uncontrolled circumstances. We find that this issue is perennial

DSM SINOCHEM PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHR vs. DCIT, CHANDIGARH

In the result, appeal of the assessee is partly allowed

ITA 253/CHANDI/2016[2011-12]Status: DisposedITAT Chandigarh20 Jan 2022AY 2011-12

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018(िन.व.2014-15) ITA NO.253/Chd./2026 (A.Y.2011-12) ITA NO.1592/Chd./2018 (A.Y.2014-15) payment in uncontrolled circumstances. We find that this issue is perennial

M/S CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHAR vs. ADDITINAL/JOINT/DEPUTY/ASSTT. C.IT,ITO,NEAC, DELHI

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

ITA 102/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh18 Jun 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 144

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar payment in uncontrolled circumstances. We find that this issue is perennial in nature, the TPO has been consistently making TP adjustment in respect of corporate services fee for similar reasons. The co-ordinate bench in appeal