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58 results for “transfer pricing”+ Section 12Aclear

Sorted by relevance

Delhi58Mumbai40Pune21Bangalore18Ahmedabad18Lucknow15Jaipur14Visakhapatnam12Hyderabad7Indore5Cochin4Cuttack3Agra3Chandigarh3Rajkot3Allahabad3Nagpur3Kolkata2Jodhpur2Chennai2

Key Topics

Section 153A42Section 12A34Addition to Income18Section 15317Section 143(3)16Section 144C13Section 1111Section 144C(13)9Exemption9Reassessment

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

ITA 2313/DEL/2022[2018-19]Status: DisposedITAT Delhi01 May 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Kumar, CIT (DR)
Section 143(3)Section 144BSection 144C(13)Section 153(3)Section 270ASection 35Section 80GSection 80I

transfer pricing provisions in the final assessment order is contrary to the position of law and factual matrix and thus requires to be reversed. 38. In essence, it is the case of assessee that revenue has merely alleged existence of arrangement to invoke rigours of Section 80IA(10) of the Act merely on the ground that the eligible units have

Showing 1–20 of 58 · Page 1 of 3

9
TDS9
Section 133A8

GHAZIABAD DEVELOPMENT AUTHORITY,GHAZIABAD vs. DCIT E (CIRCLE), GHAZIABAD

In the result, the appeal of the assessee in ITA

ITA 305/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Feb 2024AY 2018-19

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

prices generating profits. Besides the assessee has substantial income in the nature of rental/lease/ hiring income. It is also understood that the disposal of properties by the assessee authority is by several modes including draw of lots lottery and auction. The very nature of such disposal contemplates sale to the highest bidder presumably generating profits or to unidentified persons

GHAZIABAD DEVELOPMENT AUTHORITY,GHAZIABAD vs. DCIT CIRCLE EXEMPTION, GHAZIABAD

In the result, the appeal of the assessee in ITA

ITA 589/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Feb 2024AY 2016-17
Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

prices generating profits. Besides the assessee has substantial income in the nature of rental/lease/ hiring income. It is also understood that the disposal of properties by the assessee authority is by several modes including draw of lots lottery and auction. The very nature of such disposal contemplates sale to the highest bidder presumably generating profits or to unidentified persons

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

In the result, the appeal of the Revenue is dismissed

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17
Section 11Section 12ASection 143(3)

price permissible under prevailing stamp\nduty law. The AO further observed that the entire sale consideration was given to\nother entity as donation. Accordingly, ld. CIT DR submits that assessee is not carried\nout any charitable activity nor any income was ever derived from such land which\nwas sold during the year and further entire consideration was transferred as donation

HEMKUNT FOUNDATIONS,GURUGRAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL) -1, DELHI, DELHI

In the result, the appeal filed by assessee is allowed and the Stay

ITA 631/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jun 2025AY 2021-22

Bench: Shri M. Balaganesh & Shri Vimal Kumarassessment Year: 2021-22 & Stay Application No.329Del/2024 ( In Ita No. 631/Del/2024 ) Assessment Year: 2021-22 Hemkunt Foundations, Vs. Principal Commissioner Plot No.809, Second Floor, Income Tax, Rd 42, Sector 42, Central-1, Gurugram, Haryana New Delhi Pin: 122 002 Pan No. Aaath8443C (Appellant) (Respondent)

For Appellant: S/Shri Salil Kapoor, SumitFor Respondent: Shri Sunil Agarwal, Special Counsel and Shivansh Pandya, Jr. Standing
Section 12ASection 133ASection 143(2)Section 80G

transfer u/s 127. This position has been confirmed by a Constitution Bench of Supreme Court in Kashiram Aggarwala Vs UOI ((1965) 56 ITR 14 (SC). [ Attached @ S. No 3 in Revenue's Judgement PB II] D (iv) It is well-settled that non-mentioning of correct section number, or quoting wrong section number in an Order does not invalidate

MICRO FINANCE INDUSTRY NETWORK,GURGAON vs. CIT(E), CHANDIGARH

In the result, the appeals of the assessee are allowed for statistical purpose

ITA 5878/DEL/2025[-]Status: DisposedITAT Delhi11 Mar 2026
Section 12ASection 12A(1)(ac)Section 80G

pricing\nand what factors do they consider in choosing\na credit product. To bridge these knowledge\ngaps and understand customers' thoughts and\nperspectives on these issues, customers who\ncalled on MFIN CGRM were surveyed.\nCentre meeting: There has been increasing\nfeedback about the dilution in the culture of\ncentre meetings. Delinquencies arising from\nthe demonetization phase and now Covid

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 2284/DEL/2022[2018-19]Status: DisposedITAT Delhi06 Feb 2024AY 2018-19

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Vivek Kumar Upadhyay, Sr. DR
Section 143(3)Section 234BSection 40Section 801A(4)(i)Section 80I

transfer pricing adjustment on account of interest on advance. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi proceeded to frame draft order under section 144C of the Act dated 25.09.2021. He computed the total income of the assessee at Rs. 30,92,31,440/- as under:- Total income as per return Rs. (-) 3,56,94,313/- Add: Adjustment

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2634/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2633/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2632/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2635/DEL/2022[2020-21]Status: DisposedITAT Delhi02 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2845/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2846/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2844/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

YOUNG INDIAN,NEW DELHI vs. ACIT(E), NEW DELHI

ITA 1251/DEL/2019[2011-12]Status: DisposedITAT Delhi31 Mar 2022AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Amit Shukla(Through Video Conference)

For Appellant: Shri Saurabh Soparkar, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Special Counsel
Section 12ASection 143Section 143(3)Section 147Section 28Section 56(2)Section 56(2)(viia)

transferred it to Mrs. Sonia Gandhi. 6. Later on, the appellant company applied for registration u/s 12A read with section 12AA of the Act on 31.03.2010 before DIT Exemptions Delhi. The appellant was granted registration u/s 12AA by Director of Income-tax (Exemption) vide order dated 09.05.2011, i.e., w.e.f AY 2011-12, subject to various terms and conditions

MICRO FINANCE INDUSTRY NETWORK,GURGAON vs. CIT(E), CHANDIGARH

In the result, the appeals of the assessee are allowed for statistical purpose

ITA 5879/DEL/2025[-]Status: DisposedITAT Delhi11 Mar 2026
Section 12ASection 12A(1)(ac)Section 80G

pricing\nand what factors do they consider in choosing\na credit product. To bridge these knowledge\ngaps and understand customers' thoughts and\nperspectives on these issues, customers who\ncalled on MFIN CGRM were surveyed.\nCentre meeting: There has been increasing\nfeedback about the dilution in the culture of\ncentre meetings. Delinquencies arising from\nthe demonetization phase and now Covid

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

Transfer Pricing Officer (TPO) under section 92CA of the Act. During such proceedings, - the TPO, vide notice dated 25.02.2021, inter-alia, required the assessee to submit the details of change in shareholding structure and other international transactions [refer pages 97-98 of paperbook]; and - in response thereto, the appellantvide reply dated 07.07.2021 submitted (as Annexure-11 to the reply

ERICSSON INDIA PRIVATE LIMITED (FORMERLY KNOWN AS ERICSSON INDIA GLOBAL SERVICES PRIVATE LIMITED),DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (DCIT), NEW DELHI

In the result, all ITA Nos

ITA 6094/DEL/2024[2021-22]Status: DisposedITAT Delhi22 Jan 2026AY 2021-22

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5493/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Nec Corporation India Private Limited, Assessment Unit, A-31, 1St Floor, Lajpat Nagar, South Delhi, Delhi. Vs. Circle 16(1), C.R.Bldg, Pan No.Aaccn3496J I.P. Estate, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Arun Bhaduria, Advocate (Virtual) &Shri Nishank Vashistha, Adv Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.5856/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Lintec India Private Limited, Deputy Commissioner Of 14Th Floor, Eros Corporate Tower, Vs. Income Tax, Nehru Place, South Delhi. Circle 13(1), C.R. Building,Delhi. Pan No.Aaccl3772F अपीलाथ" Appellant ""यथ"/Respondent

Section 144C(13)Section 92C

12A, Ground Floor, Prakash Deep Building, Range-42, C.R. Building, S.O. Connaught Place, New Delhi. ITO, New Delhi. PAN No.AACCG4036D अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Devansh Jain, Advocate Shri Dharm Veer Singh, CIT DR Revenue by सुनवाईक"तारीख/ Date of hearing: 22.01.2026 22.01.2026 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PER SANJAY AWASTHI, ACCOUNTANT

NEC CORPORATION INDIA PRIVATE LIMITED,DELHI vs. DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 16(1), DELHI

In the result, all ITA Nos

ITA 5493/DEL/2024[2021-22]Status: DisposedITAT Delhi22 Jan 2026AY 2021-22

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5493/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Nec Corporation India Private Limited, Assessment Unit, A-31, 1St Floor, Lajpat Nagar, South Delhi, Delhi. Vs. Circle 16(1), C.R.Bldg, Pan No.Aaccn3496J I.P. Estate, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Arun Bhaduria, Advocate (Virtual) &Shri Nishank Vashistha, Adv Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.5856/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Lintec India Private Limited, Deputy Commissioner Of 14Th Floor, Eros Corporate Tower, Vs. Income Tax, Nehru Place, South Delhi. Circle 13(1), C.R. Building,Delhi. Pan No.Aaccl3772F अपीलाथ" Appellant ""यथ"/Respondent

Section 144C(13)Section 92C

12A, Ground Floor, Prakash Deep Building, Range-42, C.R. Building, S.O. Connaught Place, New Delhi. ITO, New Delhi. PAN No.AACCG4036D अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Devansh Jain, Advocate Shri Dharm Veer Singh, CIT DR Revenue by सुनवाईक"तारीख/ Date of hearing: 22.01.2026 22.01.2026 उ"ोषणाक"तारीख/Pronouncement on आदेश /O R D E R PER SANJAY AWASTHI, ACCOUNTANT

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 2283/DEL/2022[2017-18]Status: DisposedITAT Delhi03 Nov 2023AY 2017-18

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(1)Section 143(3)Section 40Section 801A(4)(i)Section 80I

Transfer Pricing Officer (“TPO”) who vide his order dated 29.01.2021 proposed adjustment of Rs. 1,14,41,802/- on account of interest on advance given to BSC C&C JV Nepal Ltd. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi (“FAO”) 3 proceeded to frame draft order under section 144C of the Act. He computed the total income