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15 results for “transfer pricing”+ Section 234clear

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Key Topics

Section 26316Section 143(2)16Section 25312Section 142(1)12Section 14810Section 250(6)8Section 246A8Section 143(3)8Reopening of Assessment

M/S JOSAN INDUSTRIES,JALALABAD vs. DCIT, CL-1, INTL. TAXATION, CHANDIGARH

In the result, the appeal is partly allowed as indicated

ITA 64/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh19 Mar 2024AY 2013-14

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita Nos. 64 To 66/Chd/2023 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Josan Industries, Vs. The Dcit Circle-1, बनाम Jalalabad, International Taxation, H.O., Guruharshai, Chandigarh Punjab "थायी लेखा सं./Pan No. Aaafj7294F अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri J.S. Kahlon, CIT DR
Section 144CSection 147Section 148Section 234Section 68

234 A and B which is not chargeable. 2. The facts are that a draft assessment order us 144C of the Income Tax Act, 1961 (in short 'the Act') was passed by the DCIT (Int.Tax.), Chandigarh on 14.3.2022. 3. The Assessee filed the following objections before the DRP against the Draft Assessment Order:- 1. That the Ld. Assessing Officer passing

3
Addition to Income3
Undisclosed Income3
Deduction2

M/S JOSAN INDUSTRIES,JALALABAD vs. DCIT, CL-1, INTL. TAXATION, CHANDIGARH

In the result, the appeal is partly allowed as indicated

ITA 66/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh19 Mar 2024AY 2015-16

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita Nos. 64 To 66/Chd/2023 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Josan Industries, Vs. The Dcit Circle-1, बनाम Jalalabad, International Taxation, H.O., Guruharshai, Chandigarh Punjab "थायी लेखा सं./Pan No. Aaafj7294F अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri J.S. Kahlon, CIT DR
Section 144CSection 147Section 148Section 234Section 68

234 A and B which is not chargeable. 2. The facts are that a draft assessment order us 144C of the Income Tax Act, 1961 (in short 'the Act') was passed by the DCIT (Int.Tax.), Chandigarh on 14.3.2022. 3. The Assessee filed the following objections before the DRP against the Draft Assessment Order:- 1. That the Ld. Assessing Officer passing

M/S JOSAN INDUSTRIES,JALALABAD vs. DCIT, CL-1, INTL. TAXATION, CHANDIGARH

In the result, the appeal is partly allowed as indicated

ITA 65/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh19 Mar 2024AY 2014-15

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita Nos. 64 To 66/Chd/2023 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Josan Industries, Vs. The Dcit Circle-1, बनाम Jalalabad, International Taxation, H.O., Guruharshai, Chandigarh Punjab "थायी लेखा सं./Pan No. Aaafj7294F अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri J.S. Kahlon, CIT DR
Section 144CSection 147Section 148Section 234Section 68

234 A and B which is not chargeable. 2. The facts are that a draft assessment order us 144C of the Income Tax Act, 1961 (in short 'the Act') was passed by the DCIT (Int.Tax.), Chandigarh on 14.3.2022. 3. The Assessee filed the following objections before the DRP against the Draft Assessment Order:- 1. That the Ld. Assessing Officer passing

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 61/CHANDI/2013[2009-10]Status: DisposedITAT Chandigarh19 Jul 2024AY 2009-10

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

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

transfer to a new business of machinery or plant previously used for any purpose." The perusal of relevant provisions of Section 80IC reveals that to become eligible for 80IC deduction, an assessee must satisfy the conditions mentioned in sub section (2) & (4), which are, in other words, qualifying provisions for exemption u/s 80IC of the Income Tax Act 1961. Eligibility

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 388/CHANDI/2012[2007-08]Status: DisposedITAT Chandigarh19 Jul 2024AY 2007-08

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

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

transfer to a new business of machinery or plant previously used for any purpose." The perusal of relevant provisions of Section 80IC reveals that to become eligible for 80IC deduction, an assessee must satisfy the conditions mentioned in sub section (2) & (4), which are, in other words, qualifying provisions for exemption u/s 80IC of the Income Tax Act 1961. Eligibility

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 817/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh25 Nov 2024AY 2014-15

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 177/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh25 Nov 2024AY 2013-14

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 796/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh25 Nov 2024AY 2018-19

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 795/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh25 Nov 2024AY 2017-18

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 794/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh25 Nov 2024AY 2016-17

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 84/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh25 Nov 2024AY 2020-21

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 748/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh25 Nov 2024AY 2010-11

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 818/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh25 Nov 2024AY 2015-16

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

M/S H.P.STATE FOREST COPRN. LTD.,SHIMLA vs. JCIT, S.R., SHIMLA

In the result, the present appeal of Appellant/Assessee is allowed and impugned order of Ld

ITA 280/CHANDI/2000[1990-91]Status: DisposedITAT Chandigarh06 Jun 2024AY 1990-91

Bench: Shri Vikram Singh Yadav& Shri Paresh M. Joshiआयकरअपीलसं./Ita Nos.280& 281/Chd/2000 िनधा"रणवष" / Assessment Years : 1990-91& 1991-92 M/S H.P. State Forest Corp. Ltd. Vs The Jcit, Van Nigam Kasumpti Shimla Shimla "ायीलेखासं./Pan No: Aaach4036L अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रतीक"ओरसे/Assessee By: Shri Y.K. Sud, Ca राज"वक"ओरसे/ Revenue By : Sh.Sarabjeet Singh, Cit-Dr सुनवाईक"तारीख/Date Of Hearing : 28.05.2024 उदघोषणाक"तारीख/Date Of Pronouncement : 06.06.2024 Hybridhearing आदेश/Order Per Paresh M. Joshi, Jm: Both The Above Appeals Have Been Filed By The Assessee. Since The Issues Involved In Both The Above Appeals Are Common & Were Heard Together Therefore They Are Being Disposed Off By This Consolidated Order For The Sake Of Brevity. We Shall Take Appeal Of The Assessee In Ita No. 280/Chd/2000 As A Lead Case.

For Appellant: Shri Y.K. Sud, CAFor Respondent: Sh.Sarabjeet Singh, CIT-DR
Section 139(9)Section 142(1)Section 143(1)(a)Section 143(2)Section 144Section 148Section 148(1)Section 151(2)Section 250Section 253

section 143(2) and 142(1) were issued to the Assessee from time to time and ultimately the Assessment was completed u/s 144 of the IT Act, 1961 on 31/03/1994 at the Returned income of Rs.92,52,000/- for the reasons given in the Assessment Order. The assessment framed by the Assessing Officer was confirmed by CIT(A), Shimla vide

M/S H.P.STATE FOREST COPRN. LTD.,SHIMLA vs. JCIT, S.R., SHIMLA

In the result, the present appeal of Appellant/Assessee is allowed and impugned order of Ld

ITA 281/CHANDI/2000[1991-92]Status: DisposedITAT Chandigarh06 Jun 2024AY 1991-92

Bench: Shri Vikram Singh Yadav& Shri Paresh M. Joshiआयकरअपीलसं./Ita Nos.280& 281/Chd/2000 िनधा"रणवष" / Assessment Years : 1990-91& 1991-92 M/S H.P. State Forest Corp. Ltd. Vs The Jcit, Van Nigam Kasumpti Shimla Shimla "ायीलेखासं./Pan No: Aaach4036L अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रतीक"ओरसे/Assessee By: Shri Y.K. Sud, Ca राज"वक"ओरसे/ Revenue By : Sh.Sarabjeet Singh, Cit-Dr सुनवाईक"तारीख/Date Of Hearing : 28.05.2024 उदघोषणाक"तारीख/Date Of Pronouncement : 06.06.2024 Hybridhearing आदेश/Order Per Paresh M. Joshi, Jm: Both The Above Appeals Have Been Filed By The Assessee. Since The Issues Involved In Both The Above Appeals Are Common & Were Heard Together Therefore They Are Being Disposed Off By This Consolidated Order For The Sake Of Brevity. We Shall Take Appeal Of The Assessee In Ita No. 280/Chd/2000 As A Lead Case.

For Appellant: Shri Y.K. Sud, CAFor Respondent: Sh.Sarabjeet Singh, CIT-DR
Section 139(9)Section 142(1)Section 143(1)(a)Section 143(2)Section 144Section 148Section 148(1)Section 151(2)Section 250Section 253

section 143(2) and 142(1) were issued to the Assessee from time to time and ultimately the Assessment was completed u/s 144 of the IT Act, 1961 on 31/03/1994 at the Returned income of Rs.92,52,000/- for the reasons given in the Assessment Order. The assessment framed by the Assessing Officer was confirmed by CIT(A), Shimla vide