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195 results for “transfer pricing”+ Section 47clear

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Key Topics

Addition to Income40Section 143(3)38Section 26329Section 69A28Section 143(2)24Section 43C21Section 153A20Section 14817Section 127

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

47) is extended w.e.f. assessment year 1988-89 to include any transaction involving the possession of any immovable property to be taken or retained in part performance of a contract of the nature referred to in Section 53A of the T.P. Act. A combined reading of the two sections shall infer that unless the transferee is unconditionally willing and ready

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

Showing 1–20 of 195 · Page 1 of 10

...
16
Penalty11
Deduction8
Disallowance7

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

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

47) is extended w.e.f. assessment year 1988-89 to include any transaction involving the possession of any immovable property to be taken or retained in part performance of a contract of the nature referred to in Section 53A of the T.P. Act. A combined reading of the two sections shall infer that unless the transferee is unconditionally willing and ready

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

M/S OM CONTRACTOR AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

ITA 485/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR
Section 133(6)Section 148Section 44A

47,393/- from M/s S.P. Singla Construction (Pvt.) Ltd and Rs. 2,015,306/- from M/s SPS Structures Ltd. during the year under consideration. Allegedly, no actual work had been done by this assessee firm as per the information. The AO proceeded to make inquires u/s 133(6) of the Income Tax Act, 1961 [in short

M/S SHIV SHAKTI CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

ITA 481/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR
Section 133(6)Section 148Section 44A

47,393/- from M/s S.P. Singla Construction (Pvt.) Ltd and Rs. 2,015,306/- from M/s SPS Structures Ltd. during the year under consideration. Allegedly, no actual work had been done by this assessee firm as per the information. The AO proceeded to make inquires u/s 133(6) of the Income Tax Act, 1961 [in short

M/S OMKAR ENGINEER AND CONTRACTOR,SANGRUR vs. PCTI, PATIALA

The appeals of the assessees stand allowed

ITA 484/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR
Section 133(6)Section 148Section 44A

47,393/- from M/s S.P. Singla Construction (Pvt.) Ltd and Rs. 2,015,306/- from M/s SPS Structures Ltd. during the year under consideration. Allegedly, no actual work had been done by this assessee firm as per the information. The AO proceeded to make inquires u/s 133(6) of the Income Tax Act, 1961 [in short

M/S MAA BHAGWATI ENTERPRISES,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

ITA 483/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR
Section 133(6)Section 148Section 44A

47,393/- from M/s S.P. Singla Construction (Pvt.) Ltd and Rs. 2,015,306/- from M/s SPS Structures Ltd. during the year under consideration. Allegedly, no actual work had been done by this assessee firm as per the information. The AO proceeded to make inquires u/s 133(6) of the Income Tax Act, 1961 [in short

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

ITA 454/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh29 Jan 2025AY 2011-12

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

For Appellant: Shri Yogesh Monga, CAFor Respondent: Shri Vivek Vardhan, JCIT-Sr.DR
Section 143(2)Section 148Section 250Section 253Section 48Section 50C

price at Rs.2,42,00,000/-. The question is when long term gain or short term gain arises. It is on the date on which an asset (whether long term or short term) is transferred. As per section 2(47

DY.CIT, CIRCLE-1(1), CHANDIGARH vs. M/S GLAXOSMITHKLINE CONSUMER PVT. LTD., NABHA

In the result, Revenue’s appeal is dismissed

ITA 121/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh16 Oct 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 121/Chd/2023 "नधा"रण वष" / Assessment Year : 2016-17 Dcit, M/S Glaxosmithkline Circle 1(1), बनाम Consumer Pvt. Ltd., Chandigarh Patiala Road, Vs. Nabha. Punjab "थायी लेखा सं./Pan No. Aafcg8415R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Ajay Vohra, Sr. Advocate With Sh. Neeraj Jain, Advocate & Ms. Somya Jain, Ca (Virtual) राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.10.2025 आदेश/Order Per Krinwant Sahay, Am:

For Appellant: Sh. Ajay Vohra, Sr. Advocate with Sh. Neeraj Jain, Advocate and Ms. Somya Jain, For Respondent: Shri Manav Bansal, CIT DR
Section 32(1)

47 (Del Trib.) - I&B Seeds Pvt Ltd vs. DCIT: 142 taxmann.com 274 (Bang Trib.) 18. In view of the aforesaid, since the predecessor, viz. Novartis in the present case, has not claimed depreciation on both tangible and intangible assets forming part of the OTC business transferred to the assessee by way of slump sale, the provisions of sixth proviso

M/S CHANDIGARH BOTTLING CO.,CHANDIGARH vs. ACIT, CHANDIGARH

In the result, appeals of the assessee are allowed

ITA 605/CHANDI/2011[2006-07]Status: DisposedITAT Chandigarh29 Aug 2018AY 2006-07

Bench: Ms. Diva Singh & Dr.B.R.R.Kumar & Assessment Year: 2006-07

For Appellant: Shri Tej Mohan SinghFor Respondent: Smt.Chander Kanta, Sr.DR

47 of the Income Tax Act,1961 (emphasis supplied) 5.3. Attention was also invited to unnumbered page 4 of the assessment order wherein the issue was summed up by the assessing officer in the following manner : Further, w.r.t. the assessee's contention . "Since none of the entries made are supported by any executed or registered instrument of transfer , the same

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 226/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 227/CHANDI/2017[2010-11]Status: DisposedITAT Chandigarh26 Oct 2021AY 2010-11

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 242/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 1500/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh26 Oct 2021AY 2014-15

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 1495/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh26 Oct 2021AY 2015-16

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 220/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 221/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 225/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 222/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 219/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

transfer pricing adjustment to be made as per ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate