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692 results for “transfer pricing”+ Search & Seizureclear

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Key Topics

Section 153A127Addition to Income76Section 153C55Section 6844Section 143(3)44Section 13236Disallowance34Search & Seizure24Section 14320Unexplained Investment

ETT LTD (FORMERLY KNOWN AS INDIAN EXPRESS MULTIMEDIA LTD),NEW DELHI vs. CIT, CENTRAL-II, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3341/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Mar 2019AY 2013-14

Bench: Sh. Amit Shukla & Sh. Anadee Nath Misshraassessment Year: 2013-14

Section 115Section 143Section 14ASection 153Section 263Section 80Section 80I

transfer pricing adjustment of Rs. 10 Crore or more in an earlier assessment year and such adjustment has been upheld by the judicial authorities or is pending in appeal; and (c) where search and seizure

Showing 1–20 of 692 · Page 1 of 35

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Section 143(2)19
Section 69B19

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

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

ITA/52/2023HC Delhi02 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under section 153C of the Act was issued to the assessee on 18.11.2013.  The assessing officer made reference to the Transfer Pricing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

ITA/993/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under section 153C of the Act was issued to the assessee on 18.11.2013.  The assessing officer made reference to the Transfer Pricing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

ITA/995/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under section 153C of the Act was issued to the assessee on 18.11.2013.  The assessing officer made reference to the Transfer Pricing

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 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

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-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 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 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, 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

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

ITA 1380/DEL/2017[2012-13]Status: DisposedITAT Delhi07 Oct 2020AY 2012-13

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

Section 115JSection 143Section 144CSection 14ASection 14A(2)Section 36Section 43(5)(d)Section 80I

seizure operations carried out under the provisions of Section 132 of the act on 21/1/2011. A special audit u/s 142 (2A) was also conducted for assessment year 2004 – 05 to 2011 – 12. The assessment for the assessment year 2004 – 05 to 2011 – 12 was passed considering the findings of search of action and report of special audit. Various disallowances under

CENTAUR HELICOPTER SERVICES P.LTD. vs. COMMISSIONER OF INCOME TAX

ITA/988/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

ANUJ CHAWLA vs. COMMISSIONER OF INCOME TAX NEW

ITA/478/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

ASHOK CHAWLA vs. COMMISSIONER OF INCOME TAX NEW

ITA/495/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

COMMISSIONER OF INCOME TAX vs. ASHOK CHAWLA

ITA/817/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

COMMISSIONER OF INCOME TAX vs. CENTAUR IMPEX P.LTD.

ITA/1246/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

CENTAUR IMPEX P.LTD. vs. COMMISSIONER OF INCOME TAX NEW

ITA/479/2007HC Delhi11 Apr 2017

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260

search and seizure under Section 132. In deciding that the suit – in so far as it concerned the ownership of the gold ornaments – was barred, the Court noted at paragraph 9 as follows: “9. It (the High Court) failed to consider the effect of the decree if passed in the suit on the order under Section

HITESH MITTAL,MUMBAI vs. DCIT, CENTRAL CIRCLE, KARNAL

ITA 4445/DEL/2018[2014-15]Status: DisposedITAT Delhi07 Feb 2022AY 2014-15

Bench: Shri G.S. Pannu & Shri Kuldip Singh(Through Video Conferencing)

For Appellant: Shri Vinod Kumar Bindal, C. A.; &For Respondent: Shri J. K. Mishra [CIT] – D.R
Section 139Section 144

price of which has been paid from disclosed bank account of M/s. Satellite Exports, a proprietorship concern of the assessee. Ledger account of Goodwill Apartments available at page 48 of the paper book also shows the mode of payment through banking channels from the bank account of M/s. Satellite Exports. Conveyance Deed available at page