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360 results for “transfer pricing”+ Search & Seizureclear

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Key Topics

Section 153A95Addition to Income76Section 6862Section 143(3)60Section 153C57Section 13237Disallowance33Search & Seizure21Unexplained Investment19Natural Justice

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

ITA 1977/DEL/2020[2014-15]Status: DisposedITAT Delhi02 Sept 2022AY 2014-15

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

For Respondent: Shri Vivek Verma
Section 132Section 142Section 144C(4)Section 153ASection 80Section 801BSection 80I

transfer pricing adjustment is not sustainable under law. 76. Learned departmental representative vehemently supported order of learned transfer pricing officer and learned CIT - A. 77. We have carefully considered rival contention and perused orders of lower authorities. Facts in facts show in present case is that assessee has given a loan to its wholly owned subsidiary in Switzerland namely

Showing 1–20 of 360 · Page 1 of 18

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19
Bogus Purchases17
Section 143(2)16

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1348/DEL/2024[2018-19]Status: DisposedITAT Delhi13 Sept 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1346/DEL/2024[2015-16]Status: DisposedITAT Delhi13 Sept 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1345/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1347/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Sept 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1344/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1342/DEL/2024[2011-12]Status: DisposedITAT Delhi13 Sept 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1343/DEL/2024[2012-13]Status: DisposedITAT Delhi13 Sept 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYAPAL LTD., NEW DELHI

ITA 1976/DEL/2020[2013-14]Status: DisposedITAT Delhi02 Sept 2022AY 2013-14

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

For Respondent: Shri Vivek Verma
Section 144C(4)Section 80Section 801BSection 80I

price, which are, further transferred to eligible units at actual cost comprising of procurement cost, processing cost, freight expenses on FIFO [ 1st in 1st out] basis. Therefore, it was stated that assessee has transferred goods at total cost comprising all these cost components. Merely because silver for is also sold by appellant to third-party customers at a price higher

PICO DEEPALI OVERLAYS CONSORTIUM (BY DEEPALI DESIGNS EXHIBITS (P.) LTD.),DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI

In the result, both the captioned appeals filed by the assessee are allowed

ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

TRANSFER PRICING OFFICER ("TPO") U/S 92CA(3) DATED 27.01.2021 AND ALSO THE ADDITIONS MADE THEREIN AND THE OBSERVATIONS MADE ARE ILLEGAL, BAD IN LAW, WITHOUT JURISDICTION AND VOID AB INITIO AND IN GROSS VIOLATION OF PRINCIPLES OF NATURAL JUSTICE. 4. THAT THE FINAL ASSESSMENT ORDER IS PURPORTEDLY PASSED ON 27.01.2022 WHEREAS THE SAME HAS BEEN SERVED ON DDEPL (AS ALLEGED

PICO DEEPALI OVERLAYS CONSORTIUM,HARYANA vs. DCIT CENTRAL CIRCLE 17, DELHI

In the result, both the captioned appeals filed by the assessee are allowed

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

TRANSFER PRICING OFFICER ("TPO") U/S 92CA(3) DATED 27.01.2021 AND ALSO THE ADDITIONS MADE THEREIN AND THE OBSERVATIONS MADE ARE ILLEGAL, BAD IN LAW, WITHOUT JURISDICTION AND VOID AB INITIO AND IN GROSS VIOLATION OF PRINCIPLES OF NATURAL JUSTICE. 4. THAT THE FINAL ASSESSMENT ORDER IS PURPORTEDLY PASSED ON 27.01.2022 WHEREAS THE SAME HAS BEEN SERVED ON DDEPL (AS ALLEGED

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

ITA 5356/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jan 2026AY 2021-22
Section 132Section 143(3)Section 144C(5)Section 148Section 153

pricing adjustment particularly when all the requisite details & documents were placed before the authorities with regard to purchase of capital assets and hence, the entire erroneous addition needs to be deleted.\n13. That on the facts, law and in the circumstances of the case, the Ld. AO as well as the Ld. DRP has erred in law in making addition

XANDER ADVISORS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NOIDA

In the result, both the appeals are allowed, as indicated

ITA 1376/DEL/2016[2009-10]Status: DisposedITAT Delhi30 Aug 2022AY 2009-10

Bench: Shri G.S. Pannu & Shri Saktijit Dey

Section 132Section 144CSection 144C(1)Section 144C(15)(b)Section 153ASection 92C

transfer pricing adjustment of Rs.1,11,62,277 to the ALP of the international transaction. 5. Pertinently, a search and seizure

XANDER ADVISORS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NOIDA

In the result, both the appeals are allowed, as indicated

ITA 1377/DEL/2016[2010-11]Status: DisposedITAT Delhi30 Aug 2022AY 2010-11

Bench: Shri G.S. Pannu & Shri Saktijit Dey

Section 132Section 144CSection 144C(1)Section 144C(15)(b)Section 153ASection 92C

transfer pricing adjustment of Rs.1,11,62,277 to the ALP of the international transaction. 5. Pertinently, a search and seizure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4652/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Jan 2024AY 2010-11

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4651/DEL/2015[2009-10]Status: DisposedITAT Delhi11 Jan 2024AY 2009-10

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4653/DEL/2015[2011-12]Status: DisposedITAT Delhi11 Jan 2024AY 2011-12

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4650/DEL/2015[2008-09]Status: DisposedITAT Delhi11 Jan 2024AY 2008-09

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 5396/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jan 2024AY 2011-12

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 3356/DEL/2015[2008-09]Status: DisposedITAT Delhi10 Jan 2024AY 2008-09

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

seizure operation u/s 132 of the Income Tax Act, 1961 was conducted by the Investigation Wing of the Income Tax Department on 22.03.2012 in M/s Focus Energy CO Nos. 353 to 356 & Others/Del/2015 Rolland Enterprises Ltd. & Others . Group of cases. In the course of search operation, certain incriminating documents pertaining to the assessee were found and seized. Accordingly, notice