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176 results for “transfer pricing”+ Section 220(2)clear

Sorted by relevance

Mumbai207Delhi176Hyderabad70Bangalore64Chennai57Jaipur50Chandigarh40Raipur20Indore19Guwahati18Kolkata17Ahmedabad14Lucknow11Cochin11Rajkot7Pune6Surat5Amritsar3Ranchi1Jodhpur1

Key Topics

Addition to Income42Section 143(3)32Disallowance27Section 153C26Section 143(2)25Section 2424Deduction24Section 10A20Section 4019

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 3380/DEL/2014[2008-09]Status: DisposedITAT Delhi05 Dec 2025AY 2008-09

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 391

Showing 1–20 of 176 · Page 1 of 9

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Section 801A(4)18
Section 9(1)(vi)16
Double Taxation/DTAA16

section 55(2)(1), cost inflation index was to be applied with effect from 1-4-1981 instead of the year of acquisition by the assessee. 46. The Punjab & Haryana High Court in the case of DCIT v. Sushil Kumar: 231 Taxman 788 held that where capital asset was property of HUF prior to 1.4.1981 and assessee acquired absolute ownership

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

section 92CA. Consequently, the reference appears to be invalid, and the transfer pricing and subsequent proceedings also appear to be time barred. In this context it is necessary to make following submissions – (a) time barring being a mandate to the forum, Hon’ble Tribunal may have to decide this preliminary aspect (b) assuming time barring aspect is decided in favour

NIKESH ARORA,GURGAON vs. DCIT, INTERNATIONAL TAXATION, GURGON

In the result, appeal is allowed in the terms indicated above

ITA 1008/DEL/2022[2017-18]Status: DisposedITAT Delhi18 Jul 2024AY 2017-18

Bench: We Proceed To Deal With The Substantive Issues Arising

Section 143(3)Section 144C(13)Section 2

220/-. 4 | P a g e AY: 2017-18 Assessee’s case was selected for scrutiny. In course of assessment proceedings, the Assessing Officer made a reference to FT & TR Division seeking further information. After receiving such information as well as other details called from the assessee, the Assessing Officer proceeded with the assessment proceedings. While verifying the return

AMWAY INDIA ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 1(1), DELHI / NFAC, DELHI

Appeal of the assessee is allowed

ITA 5912/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

Section 143(1)(a)Section 143(2)Section 143(3)Section 80GSection 92C

220/- against the returned income of Rs. 77,89,22,110/-. 2. The Ld. TPO/DRP/AO has erred on facts and in law in making addition on account of "AMP Intensity" amounting to Rs.170,31,42,080/- and disallowance out of 80G deduction 2 claimed amounting to Rs.3,75,000/- and retaining adjustment of Rs. 27,41,07,030/-made

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

ITA 8361/DEL/2019[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri S. K,. Jadav, CIT DR
Section 115JSection 143(3)Section 144C(5)Section 92C

2 of the assessee is squarely covered. In view of the above, we direct the Learned TPO / AO to delete the transfer pricing adjustment made in the sum of Rs 1,20,54,020/- in respect of international transaction towards payment of royalty. 5. Ground No. 3 to 3.3 raised by the assessee is about Disallowanceofdepreciation amounting

DCIT,C-11(1), NEW DELHI vs. HERO MOTOCORP LTD.,, NEW DELHI

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

price could not have been made under that section. Further, the Tribunal held that the transactions were entered by the assessee on account of commercial expediency and when the recipients had paid tax on payments received from the assessee company, disallowance could not be made by applying provisions of section 40A(2) of the Act. It would be pertinent

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

section 90(2) of the Act, the provisions of the Act are overridden by the provisions of the India-Denmark DTAA, to the extent the provisions of the latter are more beneficial to the Assessee.In this regard, he submitted that sales commission received by the Assessee, being 6% of sales made by the LM India to entities apart from

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

220-262 of Paper Book Vol-2) striking down the ICDS as ultra vires the provisions of the Act, being in excess of delegated legislation. Section 43CB was inserted in the Act with a view to provide legal sanction to the provisions of ICDS III and ICDS IV. 20. A perusal of section 43CB would show that the same

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

220-262 of Paper Book Vol-2) striking down the ICDS as ultra vires the provisions of the Act, being in excess of delegated legislation. Section 43CB was inserted in the Act with a view to provide legal sanction to the provisions of ICDS III and ICDS IV. 20. A perusal of section 43CB would show that the same

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

220-262 of Paper Book Vol-2) striking down the ICDS as ultra vires the provisions of the Act, being in excess of delegated legislation. Section 43CB was inserted in the Act with a view to provide legal sanction to the provisions of ICDS III and ICDS IV. 20. A perusal of section 43CB would show that the same

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 715/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

220-262 of Paper Book Vol-2) striking down the ICDS as ultra vires the provisions of the Act, being in excess of delegated legislation. Section 43CB was inserted in the Act with a view to provide legal sanction to the provisions of ICDS III and ICDS IV. 20. A perusal of section 43CB would show that the same

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

220-262 of Paper Book Vol-2) striking down the ICDS as ultra vires the provisions of the Act, being in excess of delegated legislation. Section 43CB was inserted in the Act with a view to provide legal sanction to the provisions of ICDS III and ICDS IV. 20. A perusal of section 43CB would show that the same

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

2 contradiction and complete ignorance of binding directions of the Id. DRP which is against the express provisions of section 144C(10) and 144C(13) of the Act. 4. Without prejudice to the above, that the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act dated 26th July, 2022 is bad in law and the additions/disallowances made

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

2,221 FV- Rs.10/shares issued on 45,375 27.02.2018 at Rs.20.43 per share Sub-total 7,181 1,35,399 7,16,13,202 Total 134,99,99,904 45. It is pertinent to note that even after issue of aforesaid equity shares by assessee to the existing shareholders, the percentage shareholding of existing shareholders remained same

ENORMOUS NIVESH P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

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

ITA 570/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Sept 2025AY 2015-16

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2015-16 M/S. Enormous Nivesh Pvt. Vs. Assistant Commissioner Of Ltd., 1, Zamrudpur Community Income Tax, Central Circle Centre, Kailash Colony, 13, Ara Centre, New Delhi – 1100 48 Jhandewalan Extension, Pan No. Aabcd1454F Delhi -1100 55 (Appellant) (Respondent) Assessment Year: 2015-16 M/S. Fragment Nivesh P. Ltd., Vs. Assistant Commissioner Of 1, Zamrudpur Community Income Tax, Central Circle Centre, Kailash Colony, 13, Ara Centre, New Delhi – 1100 48 Jhandewalan Extension, Pan No. Aaecs5314G Delhi -1100 55 (Appellant) (Respondent)

For Appellant: Shri Manoj Kataruka, AdvFor Respondent: Shri Kumar Avikal Manu, CIT - DR
Section 142(1)Section 143(2)Section 143(3)Section 250(6)Section 56(2)

section 56(2)(vii)(c). 9.1 As per ratio of judgment rendered in the case of PCIT vs. Jigar Jashwantlal Shah, Hon'ble Gujarat High Court has held as under: “19. The apex Court in the case of Khoday Distilleries Ltd. vs. CIT & Anr. (2008) 220

FRAGMENT NIVESH P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

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

ITA 572/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Sept 2025AY 2015-16

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2015-16 M/S. Enormous Nivesh Pvt. Vs. Assistant Commissioner Of Ltd., 1, Zamrudpur Community Income Tax, Central Circle Centre, Kailash Colony, 13, Ara Centre, New Delhi – 1100 48 Jhandewalan Extension, Pan No. Aabcd1454F Delhi -1100 55 (Appellant) (Respondent) Assessment Year: 2015-16 M/S. Fragment Nivesh P. Ltd., Vs. Assistant Commissioner Of 1, Zamrudpur Community Income Tax, Central Circle Centre, Kailash Colony, 13, Ara Centre, New Delhi – 1100 48 Jhandewalan Extension, Pan No. Aaecs5314G Delhi -1100 55 (Appellant) (Respondent)

For Appellant: Shri Manoj Kataruka, AdvFor Respondent: Shri Kumar Avikal Manu, CIT - DR
Section 142(1)Section 143(2)Section 143(3)Section 250(6)Section 56(2)

section 56(2)(vii)(c). 9.1 As per ratio of judgment rendered in the case of PCIT vs. Jigar Jashwantlal Shah, Hon'ble Gujarat High Court has held as under: “19. The apex Court in the case of Khoday Distilleries Ltd. vs. CIT & Anr. (2008) 220

SONY INDIA PVT. LTD.,NEW DELHI vs. NATIOANAL E- ASSESMENT CENTRE, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 493/DEL/2021[2016-17]Status: FixedITAT Delhi17 Oct 2022AY 2016-17

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Bhaskar Goswami, CIT- DR
Section 115JSection 143(3)Section 80G

220 Operating Profit 2,239,593,461 2,775,183 OP/PR 2.77% OP/OC 15.00% 9. In order to bench mark international transaction in the nature of import of finished goods and other aggregated transactions, TNMM was considered as the most appropriate method and the ratio of operating profit to operating sales was considered as the PLI. 10. During the course

CONCENTRIX DAKSH SERVICES INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE-4(2), NEW DELHI

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

ITA 485/DEL/2021[2016-17]Status: DisposedITAT Delhi05 Mar 2024AY 2016-17

Bench: Sh. Saktijit Dey, Vice-Dr. B. R. R. Kumar

For Appellant: Sh. Ankul Goyal, AdvFor Respondent: Sh. Rajesh Kumar, CIT(DR)
Section 143(3)Section 92C

Price or not? If by providing the services/goods at a discounted rate or permitting the assessee to receive the payment after a long period of 60 days or 90 days, then it will amount to permitting the A.E. to use the working capital of the a ssessee for the purposes of earning the profit. No prudent business man would venture

GENPACT CONSULTING (SINGAPORE) PTE. LTD. (EARLIER KNOWN AS 'HEADSTRONG CONSULTING PTE. LTD.'),GURGAON vs. ACIT, CIRCLE-2(1)(1) INT. TAX., NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 501/DEL/2021[2015-16]Status: DisposedITAT Delhi13 Jun 2022AY 2015-16

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Percy Pardiwalla, Sr. AdvFor Respondent: Shri Gangadhar Panda, CIT-DR
Section 142(1)Section 2(47)Section 263Section 45Section 47

Pricing Officer. 5. A perusal of the assessment order shows that simultaneous proceedings were undertaken, one by the Assessing Officer and the other by the TPO. Notes to Indian Income tax return for Assessment Year 2015-16 reads as under: “1. Headstrong Consulting (Singapore) Pte. Limited {'HCS' or 'the Company') is a company incorporated under the laws of Singapore arid

SABRE DECISION TECHNOLOGIES INTERNATIONAL LLC,NEW DELHI vs. ACIT, INTERNATIONAL TAXATION, CIRCLE 3(1)(2), NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 5782/DEL/2017[2014-15]Status: DisposedITAT Delhi03 Jan 2023AY 2014-15

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

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 234ASection 44DSection 9Section 9(1)(vi)

transfer of any 'tangible product'. Accordingly, consideration received by SDT from its Indian customers cannot be said to be for use of a design or model Process It is submitted that no process has been used by customers of the appellant in India. The automated process taking place in SDT's servers can at most be said to be used