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44 results for “transfer pricing”+ Section 263clear

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Key Topics

Section 263105Section 143(3)39Addition to Income17Section 153A16Section 143(2)15Section 142(1)14Section 10(38)14Section 80I14Section 25313

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

ITA 416/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh22 May 2024AY 2017-18

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

For Appellant: Shri Rajiv Kaushal &For Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 263(1)Section 68Section 92C

section 263 which is as below is placed. 263. (1) The Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer or the Transfer Pricing

Showing 1–20 of 44 · Page 1 of 3

Long Term Capital Gains11
Limitation/Time-bar8
Condonation of Delay6

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

Transfer Pricing Officer acting in accordance with law pass order u/s 92CA(3), the same cannot be treated as erroneous by the Commissioner simply because, according to him, the order should have been written differently. Section 263

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

Transfer Pricing Officer acting in accordance with law pass order u/s 92CA(3), the same cannot be treated as erroneous by the Commissioner simply because, according to him, the order should have been written differently. Section 263

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

ITA 403/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh31 Jul 2024AY 2013-14

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

Section 263 (1) the PCIT or Chief Commissioner or Pr. Commissioner or Commissioner may call for and examine the record of any proceedings under this Act and if he considers that any order passed therein by the AO (or Transfer Pricing

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

ITA 402/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh31 Jul 2024AY 2012-13

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

Section 263 (1) the PCIT or Chief Commissioner or Pr. Commissioner or Commissioner may call for and examine the record of any proceedings under this Act and if he considers that any order passed therein by the AO (or Transfer Pricing

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

ITA 618/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-2021
For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194Section 263Section 68

section 263 of the Income Tax Act 1961,extracted by the PCIT identified five heads: (i) Provision for development expenses of Rs.100 crore; ii) Oxford Street Project, Zirakpur – investment of Rs.26.50 crore and TDS u/s 194-IA; (iii) Advances from customers Rs.64,285.60 lakh and Advance against property Rs.7,607.14 lakh; (iv) Rs.921.39 lakh “previous year taxes” appearing in Reserves

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

ITA 466/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh20 Feb 2025AY 2015-16
For Respondent: \nShri Sudhir Sehgal, Advocate
Section 142(1)Section 143(2)Section 147Section 148Section 253Section 263

Section 263\n(1) & Explanation 2 with which we are primarily concerned.\n\n263. (1) The Principal Commissioner Principal Chief Commissioner or\nChief Commissioner or Principal Commissioner or Commissioner may\ncall for and examine the record of any proceeding under this Act,\nand if he considers that any order passed therein by the Assessing\nOfficer or the Transfer Pricing

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

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

The appeals are partly allowed

ITA 322/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh29 Jul 2025AY 2011-12

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

SMT. RITU SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, both the appeals are allowed

ITA 305/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh06 Oct 2025AY 2012-13
For Appellant: Shri Ashwani Kumar, CA andFor Respondent: \nSmt. Kusum Bansal, CIT DR
Section 10(38)Section 153ASection 263

transferred to\nthe beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income tax\nAct 1961. In the meantime the operators rig the price

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

ITA 705/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh29 Apr 2025AY 2011-12
For Appellant: Shri Aditya Kumar, CAFor Respondent: Shri Rohit Sharma, CIT DR
Section 249Section 253Section 3Section 5

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

ITA 306/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh29 Apr 2025AY 2010-11
For Appellant: \nShri Aditya Kumar, CAFor Respondent: \nShri Rohit Sharma, CIT DR
Section 249Section 253Section 3Section 5

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

ITA 704/CHANDI/2019[2010-11]Status: DisposedITAT Chandigarh29 Apr 2025AY 2010-11
For Appellant: \nShri Aditya Kumar, CAFor Respondent: \nShri Rohit Sharma, CIT DR
Section 249Section 253Section 3Section 5

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

ITA 329/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh27 Feb 2025AY 2018-19

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

For Appellant: Shri Ajay Jain, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 143(3)Section 263Section 40A(3)

price with low level of construction which cannot be compared with residential house on independent plot in posh area. 15. The Ld. AR further submitted that PCIT has placed reliance on gift deed dated 8/10/2009 executed in favour of the assessee by his father. Stamp duty is charged on minimum collector for stamp duty purposes and it cannot reflect

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from other

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from other

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

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

Section 143(3)Section 263

263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from other

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from other

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from other