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100 results for “transfer pricing”+ Section 234Dclear

Sorted by relevance

Mumbai136Delhi100Bangalore18Raipur17Ahmedabad17Hyderabad11Cochin6Kolkata4Indore3Surat3Jodhpur2Guwahati2Jaipur2Pune2Ranchi1Visakhapatnam1

Key Topics

Section 14A80Section 143(3)78Addition to Income54Transfer Pricing47Section 144C39Disallowance33Section 92C26Comparables/TP25Deduction23

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

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

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

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

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Shri Mahavir Singh & Shri M. Balaganesh

Showing 1–20 of 100 · Page 1 of 5

Double Taxation/DTAA23
Section 234A20
Penalty20
Bench:
For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

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

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE-7, NEW DELHI

In the result, the appeal of the assessee is allowed and the Stay

ITA 749/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Nov 2022AY 2018-19

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2018-19]

Section 144BSection 144B(2)Section 92BSection 92CSection 92F

234D of the Act. 38. That the NFAC erred in withdrawing/ reducing interest under section 244A of the Act. 39. That the NF'AC erred in initiating penalty under section 271AA of the Act. 40. That the NFAC erred in initiating penalty under section 270AA of the Act for non-maintenance of information and documents, after specifically noting that

SPECTRIS TECHNOLOGIES PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purpose with above observations

ITA 3563/DEL/2014[2008-09]Status: DisposedITAT Delhi17 Dec 2025AY 2008-09

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2008-09] Spectris Technologies Pvt. Vs. Acit Ltd., 201-B, Second Floor, New Delhi Park Centra, Sector -30 Gurgaon Pan No. Aagcs6654R Appellant Respondent Assessee By Sh. Tarandeep Singh, Advocate Revenue By Ms. Priya Goel, Sr. Dr Date Of Hearing 10.10.2025 Date Of Pronouncement 17.12.2025 Order Per C.N. Prasad, Jm, This Appeal Is Filed By The Assessee Against The Order Of The Ld.Commissioner Of Income Tax (Appeals) -20, New Delhi Vide Order Dated 27.03.2014 For The A.Y. 2008-09. The Assessee Has Raised Following Grounds :- 1. That On The Facts & Circumstances Of The Case & In Law, The Order Passed By The Ld. Commissioner Of Income-Tax (Appeals)-Xx, New Delhi ("Cit(A)") Is Bad In Law.

Section 234BSection 92Section 92C

section 234B and 234D of the Act. That the above grounds are independent and withtout prejudice to each other. 2. The Ld. Counsel for the assessee at the outset submitted that identical issued has been decided by the Tribunal in assessee’s own case for immediate preceding year A.Y. 2007- 08 wherein the transfer pricing

SCHNEIDER ELECTRIC INDIA PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

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

ITA 1076/DEL/2016[2007-08]Status: DisposedITAT Delhi09 Apr 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kedia[Assessment Year : 2007-08] Schneider Electric India Vs Acit Pvt.Ltd., 9Th Floor, Tower C Circle-22(2) Building No.10, Dlf Cyber Room No. 226 City, Phase-Ii, Gurgaon C.R. Building Hartyana-122002 New Delhi-110002 Pan-Aabcs1642G Appellant Respondent Appellant By Shri Rohit Tiwari, Adv. & Tanya, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 17.01.2025 Date Of Pronouncement 09.04.2025

Section 10ASection 143(3)Section 144CSection 92C(2)Section 92D

transfer prices of its international transactions; Business support services segment (sub-grounds 2.09 to 2.12) 2.9. distorting the comparability analysis conducted by the Appellant in the TP Documentation and fresh search analysis; 2.10. including certain companies that are not comparable to the Appellant in terms of functions performed, assets employed and risks assumed and excluding certain comparable companies on arbitrary

AT KEARNEY LTD.- INDIA BRANCH OFFICE,GURGAON vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals of the Assessee’s in ITA Nos

ITA 959/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary, omit or substitute any of the aforesaid grounds of appeal

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. A.T. KEARNEY LTD., GURGAON

In the result, appeals of the Assessee’s in ITA Nos

ITA 1305/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary, omit or substitute any of the aforesaid grounds of appeal

AT KEARNEY LTD.- INDIA BRANCH OFFICE,GURGAON vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals of the Assessee’s in ITA Nos

ITA 960/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary, omit or substitute any of the aforesaid grounds of appeal

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. A.T. KEARNEY LTD., GURGAON

In the result, appeals of the Assessee’s in ITA Nos

ITA 1306/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary, omit or substitute any of the aforesaid grounds of appeal

MOBASE INDIA PVT. LTD. ,UTTAR PRADESH vs. ACIT , DELHI

In the result, the appeal of the assessee is allowed

ITA 243/DEL/2022[2016-17]Status: DisposedITAT Delhi27 Feb 2024AY 2016-17

Bench: Shri Saktijit Deydr. B. R. R. Kumara.Y. : 2016-17 Mobase India Pvt. Ltd., Vs The Acit, 1C, Front Part Of Front Building, National E-Assessment Centre, Udyog Vihar, Ecotech-Ii, Greater New Delhi. Noida 201306, Up (Appellant) (Respondent) Pan No. Aaecd 8832 G Assessee By : Sh. Rajesh Dua, Ca Revenue By : Sh. Rajesh Kumar, Cit(Dr) Date Of Hearing: 06.12.2023 Date Of Pronouncement: 27.02.2024

For Appellant: Sh. Rajesh Dua, CAFor Respondent: Sh. Rajesh Kumar, CIT(DR)
Section 139(1)Section 143(3)Section 144Section 144CSection 2Section 234BSection 271(1)(c)Section 36(1)(va)Section 43(6)Section 43B

Transfer Pricing Officer u/s 92AC["the TPO"]/Draft Assessment Order passed by the Assessing Officer ["the AO"] u/s 144C dated 25/11/2019, the order passed by the Dispute Resolution Panel, New Delhi-1 ["DRP-1"] dated 27/02/2020 and the order passed by the National e-Assessment Center [NeAC] dated 30/03/2021, to the extent prejudicial to the interest of the appellant

AMERICAN EXPRESS BANKING CORP. (INDIA BRANCH),NEW DELHI vs. ADIT, CIRLCE- 1(1), INTERNATIONAL TAXATION,, NEW DELHI

In the result, the Appeal filed by the Assessee in ITA No

ITA 6253/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

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

Section 92C(3)Section 92F

234D of the Act. 20. The Learned AO has erred, in facts and in law, by initiating penalty proceedings under section 271(1)(c) of Act in relation to transfer pricing

ADIT, CIRLCE- 1(1), INTERNATIONAL TAXATION,, NEW DELHI vs. AMERICAN EXPRESS BANKING CORP. (INDIA BRANCH), NEW DELHI

In the result, the Appeal filed by the Assessee in ITA No

ITA 6455/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

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

Section 92C(3)Section 92F

234D of the Act. 20. The Learned AO has erred, in facts and in law, by initiating penalty proceedings under section 271(1)(c) of Act in relation to transfer pricing

GOLDEN AGRI RESOURCES (INDIA) P.LTD,DELHI vs. ACIT (OSD), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 1943/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2024AY 2018-19

Bench: Sh. N. K. Billaiya & Ms. Astha Chandraassessment Year: 2018-19 Golden Agri Resources Vs. Acit (Osd) ( India) Pvt. Ltd. New Delhi 208-A E-10=12 Triveni Complex, Laxmi Nagar, Delhi-1100092 Pan No.Aarcs0961K (Appellant) (Respondent) Appellant By Sh. Nishant Saini, Ar Sh. Vinamra Vij, Ar Respondent By Sh. Rajesh Kumar, Cit Dr Date Of Hearing: 18/03/2024 Date Of Pronouncement: 21/03/2024

Section 143Section 143(3)Section 144C(13)Section 270ASection 92D

Transfer Pricing ("TP") documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ("the Rules"); 3.2. rejecting the core functional analysis of the Appellant as a trader of edible oil commodities which warrants/corroborates the use of quotations from brokerage firms/ associations/exchanges for close comparability; 3.3. erroneously rejecting Other