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297 results for “transfer pricing”+ Section 13(3)clear

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Key Topics

Addition to Income50Section 143(3)48Section 26334Section 143(2)32Section 153A30Section 69A28Section 14825Section 43C21Section 132

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 136/CHANDI/2020[2010-11]Status: DisposedITAT Chandigarh27 May 2021AY 2010-11
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 29/CHANDI/2020[2015-16]Status: Disposed

Showing 1–20 of 297 · Page 1 of 15

...
18
Penalty13
Deduction9
Unexplained Investment8
ITAT Chandigarh
27 May 2021
AY 2015-16
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 30/CHANDI/2020[2016-17]Status: DisposedITAT Chandigarh27 May 2021AY 2016-17
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 3/CHANDI/2020[2011-12]Status: DisposedITAT Chandigarh27 May 2021AY 2011-12
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 27/CHANDI/2020[2013-14]Status: DisposedITAT Chandigarh27 May 2021AY 2013-14
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 137/CHANDI/2020[2011-12]Status: DisposedITAT Chandigarh27 May 2021AY 2011-12
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 2/CHANDI/2020[2010-11]Status: DisposedITAT Chandigarh27 May 2021AY 2010-11
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 28/CHANDI/2020[2014-15]Status: DisposedITAT Chandigarh27 May 2021AY 2014-15
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

3) and the Ld. Assessing officer had referred the claim of the assessee company for verification of inter unit transactions of the company and also to determine correct taxable profit of the eligible unit u/s 92CA. The Transfer Pricing Officer after verification of complete record to determine Arm's Length Price of inter unit transactions had passed the order dated

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

3) and the Ld. Assessing officer had referred the claim of the assessee company for verification of inter unit transactions of the company and also to determine correct taxable profit of the eligible unit u/s 92CA. The Transfer Pricing Officer after verification of complete record to determine Arm's Length Price of inter unit transactions had passed the order dated

M/S JSK INTERNATIONAL,BADDI vs. PR. CIT, SHIMLA

The appeal of the Assessee is Allowed

ITA 643/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh29 Nov 2018AY 2014-15
For Appellant: Shri. Satish AgarwalFor Respondent: Dr. Gulshan Raj
Section 143(3)Section 263Section 263(1)Section 40A(2)(b)Section 80I

13. Reference to Transfer Pricing Officer (TPO) 3.1 The power to determine the Arm’s Length Price (ALP) in an international transaction is contained in sub-section (3

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

ITA 396/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh10 Dec 2025AY 2016-17
For Appellant: Shri Ashray Sarna, CA(Virtual Mode)For Respondent: Shri Manav Bansal, CIT, DR
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 143(2)Section 143(3)Section 2(15)Section 250

price and no\ninterest bearing loan was used for the purpose, the addition on such account is\nnot justified. Thus, for the shake of principle of natural justice the AO should also\nget an opportunity to examine the contention of the appellant and therefore, I\ndirect the AO to verify the claim of the appellant on this issue

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

transferred to Electricity Units Consumption Manufacturing Processes Apr-14 3,900,800 932,400 2,968,400 6.72 19,947,648 May-14 3,901,000 981,900 2,919,100 6.72 19,616,352 Jun-14 4,215,000 1,033,100 3

SH. JAI RAM,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

ITA 366/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Feb 2018AY 2007-08

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Rohit GoelFor Respondent: Smt. Chandrakanta

13. In ground Nos.1, 2 & 3, assessee challenged the order of ld. CIT(Appeals) in upholding the addition of Rs. 1,88,43,554/- on account of long term capital gain on sale of agricultural land and in denying the deduction under section 54B of the Act. During the course of assessment proceedings, the Assessing Officer noted that assessee

SH. AMAR SINGH,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

ITA 365/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Feb 2018AY 2007-08

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: Sh. Rohit GoelFor Respondent: Smt. Chandrakanta

13. In ground Nos.1, 2 & 3, assessee challenged the order of ld. CIT(Appeals) in upholding the addition of Rs. 1,88,43,554/- on account of long term capital gain on sale of agricultural land and in denying the deduction under section 54B of the Act. During the course of assessment proceedings, the Assessing Officer noted that assessee

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

ITA 1135/CHANDI/2017[2014-15]Status: DisposedITAT Chandigarh04 Oct 2021AY 2014-15
For Appellant: Shri Ashray Sarna,C.AFor Respondent: Smt. Meenakshi Vohra, Addl. CIT
Section 11Section 13Section 13(1)(c)Section 13(2)(c)Section 13(3)Section 250(6)

transfer for property and as per scheme that doesn't reflect altruism on part of the members selling land to their own society. ITA 1135/CHD/2017 & ITA 700/CHD/2019 A.Y. 2014-15 & 2015-16 Page 3 of 12 7. That the Id. CIT(A)-2 Jalandhar has erred in law in deleting interest amount even when the advances paid were made

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

ITA 700/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh04 Oct 2021AY 2015-16
For Appellant: Shri Ashray Sarna,C.AFor Respondent: Smt. Meenakshi Vohra, Addl. CIT
Section 11Section 13Section 13(1)(c)Section 13(2)(c)Section 13(3)Section 250(6)

transfer for property and as per scheme that doesn't reflect altruism on part of the members selling land to their own society. ITA 1135/CHD/2017 & ITA 700/CHD/2019 A.Y. 2014-15 & 2015-16 Page 3 of 12 7. That the Id. CIT(A)-2 Jalandhar has erred in law in deleting interest amount even when the advances paid were made

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

Transfer Pricing Officer made a variation to the Arm's Length Price and valued the transaction at Rs. 517.82 per share. In other words, he recommended a variation in the Arm's Length Price. In these circumstances, the Petitioner would certainly be an eligible Assessee as contemplated under Section 144C(15)(b) (i) of the IT Act. Since this variation

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

ITA 303/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh23 Jul 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

For Appellant: Shri Ashwani Kumar &For Respondent: Smt. Kusum Bansal, CIT DR
Section 10(38)Section 132Section 143(3)Section 153ASection 153DSection 263

13. The contention of learned counsel for the appellant that the order dated 18.03.2014 was passed under Section 143(3) read with Section 263 of the Act is not well founded. Though in the heading Section 143(3)/ 263 of the Act are referred to from the order it is clear that it has been passed under Section 153A read

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

ITA 321/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh29 Jul 2025AY 2010-11

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

For Appellant: Shri Aditya Kumar, CAFor Respondent: Shri Manav Bansal, CIT DR
Section 10(38)Section 132Section 139(1)Section 143(1)Section 143(3)Section 153ASection 153DSection 263

13. The contention of learned counsel for the appellant that the order dated 18.03.2014 was passed under Section 143(3) read with Section 263 of the Act is not well founded. Though in the heading Section 143(3)/ 263 of the Act are referred to from the order it is clear that it has been passed under Section 153A read