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915 results for “transfer pricing”+ Cash Depositclear

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Key Topics

Addition to Income69Section 153A65Section 143(3)56Disallowance43Section 6838Search & Seizure17Section 13215Unexplained Investment14Section 69B

JCIT SPL. RANGE-12, NEW DELHI vs. ARIHANTA INDUSTRIES, DELHI

In the result, both the appeals of the Revenue are allowed

ITA 963/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Jul 2023AY 2015-16

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Sachit Jolly, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 131Section 68Section 801CSection 80I

transfer of funds by this party to the assessee M/s Arihanta Industries, there were cash deposits in the bank a/c of Shree MAHESHWAR Tradic Co. Further, it is also pertinent to mention here that on various occasions on a single or two consecutive days, cash in round figures is being deposited in the Bank A/c of the said party

Showing 1–20 of 915 · Page 1 of 46

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13
Bogus Purchases13
Section 14312
Section 80I12

GURCHARAN SINGH BHATIA,NEW DELHI vs. ACIT CIRCLE-47(1), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3433/DEL/2019[2014-15]Status: DisposedITAT Delhi11 Jan 2024AY 2014-15

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasad:Assessment Year: 2014-15 Shri Gurcharan Singh Bhatia, Vs. Acit, C-9, Westend Colony, Circle 47(1), New Delhi-1100 21 New Delhi (Appellant) (Respondent) (Pan:Ahnpb4697E) Assessee By : S/Shri K. Sampath & V. Rajkumar, Advocates Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 29.11.2023 Date Of Pronouncement: 11.01.2024 Order Per Challa Nagendra Prasad:This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-16, New Delhi

For Appellant: S/Shri K. Sampath & V. RajkumarFor Respondent: Shri Amit Katoch, Sr. DR
Section 37(1)Section 68

prices had come down substantially and the assessee was not able to sell the property at the proper market rate and, as such, the assessee had to bear the burden of the interest payments for the loans which were taken for the purpose of business and the assessee is in the real estate business and has undertaken various other property

ASSISTANT COMMISSIONER OF INCOME TAX, GHAZIABAD vs. JASPAL SINGH SALUJA, GHAZIABAD

Accordingly, the appeal of Revenue is dismissed in the above terms

ITA 3979/DEL/2025[2018-19]Status: DisposedITAT Delhi18 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwalasstt. Year: 2018-19 Acit Vs Shri Jaspal Singh Saluja 201-202, 2Nd Floor, R-7/21, New Raj Nagar, Cgo-1 Near Purani Hapur Ghaziabad- 201001 Chungi, Kamala Nehru Nagar, Uttar Pradesh Ghaziabad (Appellant) (Respondent) Pan No. Agpss0863Q

For Appellant: Shri R.S Ahuja, CAFor Respondent: Dr. Rajinder Kaur, CIT DR
Section 143(3)Section 144BSection 68

deposit like copy of complete cash books and ledger account along with the bank statements, month-wise break-up of cash sales and sales other than cash at different branches, month-wise break-up of the total purchases at different branches, statement of item wise purchases and sales, invoices of sales and purchases, VAT Returns, Rent Agreements, documentary evidence

ATISH SINGLA,NEW DELHI vs. ITO, WARD-43(7), NEW DELHI

In the result, appeal of the Assessee is allowed

ITA 1185/DEL/2021[2017-18]Status: DisposedITAT Delhi06 Apr 2022AY 2017-18

Bench: Shri R.K. Panda

For Appellant: Shri R.S. Singhvi, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(2)Section 68

transfer the money to SMFOOTWARE but the appellant did not furnished the nature of such payment with documentary evidence. Keeping in view the above facts, the circumstantial evidences do not support the contention of the appellant. The Hon’ble Supreme Court has held in several cases such as Sumati Dayal [1995] 214 ITR 801(SC) that while deciding any issue

HUMBOLDT WEDAG INDIA PVT. LTD.,DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 3207/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

deposits written off, deletion of addition relating to provision for warranty as well as for giving relief in respect of transfer pricing adjustment vis-a-vis intra group services. 3.6 The respective grounds raised by both the parties are as under:- 3.6.1 ITA No.567/Kol/2015 (Department’s appeal): “ 1. That the DRP has erred in law and in facts, in disallowing

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 1154/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

deposits written off, deletion of addition relating to provision for warranty as well as for giving relief in respect of transfer pricing adjustment vis-a-vis intra group services. 3.6 The respective grounds raised by both the parties are as under:- 3.6.1 ITA No.567/Kol/2015 (Department’s appeal): “ 1. That the DRP has erred in law and in facts, in disallowing

ACIT, NEW DELHI vs. M/S. HUMBOLDT WEDAG INDIA PVT. LTD., NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 1057/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

deposits written off, deletion of addition relating to provision for warranty as well as for giving relief in respect of transfer pricing adjustment vis-a-vis intra group services. 3.6 The respective grounds raised by both the parties are as under:- 3.6.1 ITA No.567/Kol/2015 (Department’s appeal): “ 1. That the DRP has erred in law and in facts, in disallowing

DCIT, NEW DELHI vs. SH. PAWAN KUMAR GUPTA, DELHI

Accordingly, ground number 7 of the appeal for assessment year 2011-12 is dismissed

ITA 3358/DEL/2014[2011-12]Status: DisposedITAT Delhi28 Dec 2018AY 2011-12

Bench: Shri Prashant Maharishi & Shri K.N.Chary

For Appellant: NoneFor Respondent: Smt Sulekha Verma, CIT DR
Section 69

cash from VISCO Ltd and Gee Ispat group and issued cheques/DDs/RTGS in lieu of the cash received. When the AO he has no basis for holding the entire such amount as unexplained investment u/s 69 even on protective basis. He has further submitted that the AO himself admits in the assessment order that, on the basis of the search

DCIT, I.T.O. DELHI vs. RATHI STEEL AND POWER LIMITED, DELHI

In the result the appeal of the Revenue stands dismissed

ITA 2720/DEL/2024[2017-2018]Status: DisposedITAT Delhi10 Nov 2025AY 2017-2018

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.2720/Del/2024, A.Y. 2017-18 Dy. Commissioner Of Vs. Rathi Steel & Power Ltd., Income Tax, Circle-19(1), Chauhan Market, Room No. 221, 2Nd Floor, Madanpur Khadar, C. R. Building, I. P. Estate Near Shopping Complex, New Delhi Sarita Vihar, New Delhi-76 Pan: Aaacr1435K (Appellant) (Respondent) Appellant By Sh. Mayank Patawari, Advocate Respondent By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 13/08/2025 Date Of Pronouncement 10/11/2025 Order Per Avdhesh Kumar Mishra, Am The Appeal Of The Revenue For Assessment Year (‘Ay’) 2017-18 Is Directed Against The Order Dated 27.03.2024 Of The Commissioner Of Income Tax (Appeals)-26, New Delhi [‘Cit(A)’].

Section 68

price on ex-godown basis. To substantiate the above said reply, the assessee company had duly submitted complete details of sale of such defective materials (Refer Pg 638-646 of PB), from which it is evident that an aggregate of 326 items had been sold through the consignment agents. Further, the Ld. AO did not issue a valid show-cause

ITO, WARD-17(1), NEW DELHI vs. MOMENTUM TECHNOLOGIES P.LTD, NEW DELHI

In the result ground number 1, 2 of the appeal are dismissed

ITA 5802/DEL/2017[2011-12]Status: DisposedITAT Delhi31 Mar 2021AY 2011-12

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Aman Preet, Sr. D.R
Section 68

cash deposits from various geography and places like Haldwani & Jalalndhar in the bank account and subsequently transferred to other parties. The assessee explained that the bank account was open for the purpose of maintaining of volume of orders procured through the assessee against which he was entitled for a commission of at the rate of 1% of the order value

M/S. AGILENT TECHNOLOGIES (INTERNATIONAL) PVT. LTD.,GURGAON vs. ACIT, GURGAON

In the result ground No. 3 of the appeal of the assessee is allowed

ITA 1255/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Sept 2016AY 2009-10

Bench: Smt Diva Singh & Shri Prashant Maharishiagilent Technologies Acit, (International) Pvt. Ltd, Circle-1, Vs. Plot No.-Cp-11, Sector-8, Gurgaon Imt Mangsar, Gurgaon Pan: Aadca4115C (Appellant) (Respondent)

For Appellant: Mr. Kanchan KaushalFor Respondent: Mr. Sunil Sharma, CIT DR
Section 143(3)Section 144CSection 234ASection 271(1)(c)Section 92

cash management requirements of universal, retail and corporate banks worldwide. It is further mentioned that that this Agilent Technologies ( International ) Private Limited V ACIT ITA No 1255/Del/2014 A Y 2009-10 Page 11 of 22 software currently powers 114 banks across the 62 countries helping them serve more than 25,000 branches, 244 million customers, 297 million accounts and over

KUNDAN RICE MILLS LTD.,DELHI vs. ACIT, KARNAL

In the result, all the appeals of the department as well as the cross objections of the assessee are allowed for statistical purposes

ITA 31/DEL/2015[2005-06]Status: DisposedITAT Delhi30 Nov 2015AY 2005-06

Bench: Shri N.K.Saini & Shri C.M. Garg

For Appellant: Shri Ved Jain, CAFor Respondent: Shri Gajanand Meena, CIT-DR
Section 133ASection 145Section 153A

cash deposit in their account and subsequently transferred to your account. The AO accordingly rejected the books of account u/s 145(3) of the Act by relying on the following case laws: 1. Arihant Builders, Developers & Investors (P) Ltd. Vs ACIT (ITAT, SB-Ind) 106 ITD 10 2. Dwarka Prasad Bajaj Vs CIT (Cal) 181 ITR 277 3. Ram Chandra

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7637/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2019AY 2014-15

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 1944/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2019AY 2012-13

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

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

ITA 5026/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 1308/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Nov 2019AY 2010-11

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

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

ITA 4913/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7112/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2019AY 2013-14

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

deposit of TDS without appreciating that such interest is an allowable expenditure under section 37(1) of the Act. 7. That the DRP erred on facts and in law in alternatively disallowing u/s 37(1), the payment of corporate charges amounting to Rs 29,69,39,832. 41 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018; 7112 & 1944/Del/2017 Transfer Pricing Issues 8. That

ITO, NEW DELHI vs. SH. VISHNU GOEL, DELHI

In the result appeal filed by the learned assessing officer are allowed for statistical purposes

ITA 3931/DEL/2015[2004-05]Status: DisposedITAT Delhi15 Oct 2018AY 2004-05

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Shivir Bajaj, CAFor Respondent: Shri S.S.Rana, CIT DR
Section 133Section 133ASection 271

cash was received from food grain merchants, which was deposited in the bank accounts of such (Assessment Year: 2004-05 and 2005-06) ITO V Vishnu Goel bogus concerns and dubious individuals against which cheques, pay orders, demand drafts were issued in favour of the beneficiaries. 04. The background facts of the whole case is recorded by the learned assessing

ITO, NEW DELHI vs. SH. VISHNU GOEL, DELHI

In the result appeal filed by the learned assessing officer are allowed for statistical purposes

ITA 3930/DEL/2015[2005-06]Status: DisposedITAT Delhi15 Oct 2018AY 2005-06

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Shivir Bajaj, CAFor Respondent: Shri S.S.Rana, CIT DR
Section 133Section 133ASection 271

cash was received from food grain merchants, which was deposited in the bank accounts of such (Assessment Year: 2004-05 and 2005-06) ITO V Vishnu Goel bogus concerns and dubious individuals against which cheques, pay orders, demand drafts were issued in favour of the beneficiaries. 04. The background facts of the whole case is recorded by the learned assessing