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4 results for “transfer pricing”+ Section 92Eclear

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Key Topics

Section 143(3)6Section 2635Section 271A4Transfer Pricing4Section 92C3Section 80I2Section 92B2Deduction2Penalty2

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

Transfer Pricing Officer (TPO). Sub-section (3) of Section 92CA provides that the TPO, after taking into account the material available with him shall, by an order in writing, determine the ALP in accordance with sub section (3) of Section 92C of the Act. Sub-section (4) of Section 92CA provides that on receipt of the order

Comparables/TP2
Addition to Income2

SARASWATI AGRO CHEMICALS (INDIA) PVT. LTD,MOHALI vs. DCIT, CIRCLE-6(1), MOHALI

In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed

ITA 165/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh15 Oct 2024AY 2014-15

Bench: Or At The Time Of Hearing.”

For Appellant: Shri R.K. Gupta, C.A and Shri Akshun Gupta, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 92BSection 92C

Transfer Pricing Officer the aggregate value of specified domestic transactions has been taken from the Form 3CEB filed by the appellant. Perusal of Form 3CEB, prescribed under Rule 10E, states as "Report from an accountant to be furnished under section 92E

M/S YAMUNA POWER & INFRASTRUCTURE LTD.,JAGADHRI vs. DCIT, CIRCLE, YAMUNANAGAR

In the result, the appeal of the assessee is allowed

ITA 1229/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh19 Jul 2024AY 2014-15

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 143(3)Section 271ASection 80ISection 92C

Section 92E and reporting of transactions with AE is necessary for the AO and the TPO to examine the transfer pricing

PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

In the result, the appeal of the Assessee is partly allowed

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR
Section 143(3)Section 234BSection 271(1)(C)

section 92E of the Income Tax Act, 1961 (2022) issued by the Institute of Chartered Accountants of India. The relevant extract thereof read as follows: '6.56 The introduction of the Other Method as the sixth method allows the use of 'any method' which takes into account (i) the price which has been charged or paid or (ii) would have been