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174 results for “transfer pricing”+ Section 80clear

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Key Topics

Section 26336Addition to Income29Section 43C21Section 153A18Section 143(3)17Section 250(6)15Section 80I14Section 13(3)14Section 132

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- 1(3)(1), Delhi examined the documentation prescribed under Rule 10D and other details were called for and examined and passed order under section 92CA(3) dt. 31/07/2021 holding that in view of the functional and economic analysis of the assessee and comparables which have been examined, no adverse inference is drawn in respect of the Specified Domestic

Showing 1–20 of 174 · Page 1 of 9

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10
Deduction8
Disallowance8
Exemption8

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- 1(3)(1), Delhi examined the documentation prescribed under Rule 10D and other details were called for and examined and passed order under section 92CA(3) dt. 31/07/2021 holding that in view of the functional and economic analysis of the assessee and comparables which have been examined, no adverse inference is drawn in respect of the Specified Domestic

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

price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller till the encashment of cheque on 15.06.2008 and cultivation of land

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

price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller till the encashment of cheque on 15.06.2008 and cultivation of land

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

section 92C of the Act to the TPO for determining the arms length price in respect of specific domestic transaction undertaken by the assessee. The TPO after examining the transfer pricing adjustment and analyzing the specific domestic transaction with associated enterprises, proceeded to bench mark the power from eligible unit to non eligible unit specifically supply of electricity and steam

ITO, WARD-1, YAMUNA NAGAR vs. M/S JAMNA AUTO INDUSTRIES LTD., YAMUNA NAGAR

In the result, the appeal is dismissed

ITA 690/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sandeep Sapra, AdvocateFor Respondent: Shri Rohit Sharma, CIT- DR
Section 36(1)(iii)Section 80I

80 IC; and that the assessment in the case of the subsidiary entity, M/s Jai Suspension Systems LLP had been completed under section 143 (3) of the IT Act, vide order dated 31.3.2015, where no such addition had been made. A copy of the said assessment order dated 31.3.2015 was filed. It was contended that as such, it was evident

ITO, WARD-1, YAMUNA NAGAR vs. M/S JAMNA AUTO INDUSTRIES LTD., YAMUNA NAGAR

In the result, the appeal is dismissed

ITA 689/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh23 Jan 2024AY 2012-13

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sandeep Sapra, AdvocateFor Respondent: Shri Rohit Sharma, CIT- DR
Section 36(1)(iii)Section 80I

80 IC; and that the assessment in the case of the subsidiary entity, M/s Jai Suspension Systems LLP had been completed under section 143 (3) of the IT Act, vide order dated 31.3.2015, where no such addition had been made. A copy of the said assessment order dated 31.3.2015 was filed. It was contended that as such, it was evident

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)

80,500/- separately. In this way, the Valuerover-assessed the calculation of FMV to reduce Long Term Capital Gain Tax liability substantially. (iii) The AO has erred in accepting the fair market value of land as on 01.04.2001 at Rs. Rs.1,66,10,500/-as claimed by the assessee on the basis of the above Valuation report. (iv) Even

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. JAMES HOTELS LTD, CHANDIGARH

ITA 552/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh01 Oct 2024AY 2012-13

Bench: The Said Resolution To Enhance Authorized Share Capital.

For Appellant: Shri R.K. KapoorFor Respondent: Shri Rohit Sharma, CIT, DR
Section 143(2)Section 269SSection 271D

Transfer Pricing Officer and thereafter the Ld. AO changed the nature of transaction from share application money and treated it as loan on which notional interest was computed. Hon'ble ITAT held that AO has no power to reclassify the transaction from the share application money to loan. 12.18 It was further submitted that while levying the penalty, Additional

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

section 57.\nThe said provision reads thus:\n\"57. Deductions.-The income chargeable under the head 'Income from other\nsources' shall be computed after making the following deductions, namely :.\n(iv) in the case of income of the nature referred to in clause (viii) of sub-\nsection (2) of section 56, a deduction of a sum equal to fifty

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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 228/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh26 Oct 2021AY 2011-12

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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 47/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh26 Oct 2021AY 2013-14

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

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

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks