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24 results for “transfer pricing”+ Section 271Cclear

Sorted by relevance

Delhi24Mumbai5Kolkata2Bangalore1Jaipur1Pune1

Key Topics

Section 194C39Section 271C24Section 201(1)21TDS21Section 133A18Survey u/s 133A18Penalty17Section 271G16Section 20112Section 12A7Section 1957Deduction6

ATEPL RAHEE JOINT VENTURE,NEW DELHI vs. ACIT CIRCLE-62(1), NEW DELHI

In the result, the appeal of the assessee stands allowed

ITA 1570/DEL/2020[2015-16]Status: DisposedITAT Delhi05 Dec 2022AY 2015-16

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2015-16]

Section 1Section 2Section 271Section 271ASection 92CSection 92D

271C, section 271CA, section 271D, section 271E, section 271F, section 271FA, section 271FAB, section 271FB, section 271G, section 271GA, section 271GB, section 271H section 271-1, section 271J, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272A, sub- section (1) of section 272AA or section 272B or sub-section (1) or sub-section

Showing 1–20 of 24 · Page 1 of 2

TAPI JWIL JV,NEW DELHI vs. ITO, WARD-62(4), NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 6722/DEL/2018[2014-15]Status: DisposedITAT Delhi16 Oct 2023AY 2014-15

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 6722/Del/2018 : Asstt. Year : 2014-15 Ita No. 4873/Del/2019 : Asstt. Year : 2014-15 Tapi Jwil Jv, Vs Income Tax Officer, C/O C. S. Anand, Adv., Ward-62(4), 104, Pankaj Tower, 10, L.S.C. New Delhi Savita Vihar, Delhi-110092 (Appellant) (Respondent) Pan No. Aadat3744J Assessee By : Sh. C. S. Anand, Adv. Revenue By : Sh. Amitabh K. Sinha, Cit-Dr Date Of Hearing: 18.07.2023 Date Of Pronouncement: 16.10.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. C. S. Anand, AdvFor Respondent: Sh. Amitabh K. Sinha, CIT-DR
Section 271GSection 40A(2)(b)Section 928BSection 92D

Transfer Pricing Officer as referred to in section 92CA or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the international transaction or specified domestic transaction] for each such failure.” 16. Provisions of Section 273B are as under: “Penalty not to be imposed

TAPI JWIL JV,NEW DELHI vs. ITO, WARD-62(4), NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 4873/DEL/2019[2014-15]Status: DisposedITAT Delhi16 Oct 2023AY 2014-15

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 6722/Del/2018 : Asstt. Year : 2014-15 Ita No. 4873/Del/2019 : Asstt. Year : 2014-15 Tapi Jwil Jv, Vs Income Tax Officer, C/O C. S. Anand, Adv., Ward-62(4), 104, Pankaj Tower, 10, L.S.C. New Delhi Savita Vihar, Delhi-110092 (Appellant) (Respondent) Pan No. Aadat3744J Assessee By : Sh. C. S. Anand, Adv. Revenue By : Sh. Amitabh K. Sinha, Cit-Dr Date Of Hearing: 18.07.2023 Date Of Pronouncement: 16.10.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. C. S. Anand, AdvFor Respondent: Sh. Amitabh K. Sinha, CIT-DR
Section 271GSection 40A(2)(b)Section 928BSection 92D

Transfer Pricing Officer as referred to in section 92CA or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the international transaction or specified domestic transaction] for each such failure.” 16. Provisions of Section 273B are as under: “Penalty not to be imposed

VATIKA SOVEREIGN PARK PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-26(1), NEW DELHI

The appeals are allowed

ITA 7251/DEL/2019[2016-17]Status: DisposedITAT Delhi30 Jun 2022AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.7251 & 7252/Del/2019 (Assessment Year : 2016-17 & 2017-18) Vatika Sovereign Park Private Vs. The Assistant Commissioner Of Limited, Income Tax, 621A, 6Th Floor, Devika Towers Circle-26(1) 6-Nehru Place New Delhi New Delhi-110019 Pan No. Aafcp9383D (Appellant) (Respondent)

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

VATIKA SOVEREIGN PARK PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-26(1), NEW DELHI

The appeals are allowed

ITA 7252/DEL/2019[2017-18]Status: DisposedITAT Delhi30 Jun 2022AY 2017-18

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.7251 & 7252/Del/2019 (Assessment Year : 2016-17 & 2017-18) Vatika Sovereign Park Private Vs. The Assistant Commissioner Of Limited, Income Tax, 621A, 6Th Floor, Devika Towers Circle-26(1) 6-Nehru Place New Delhi New Delhi-110019 Pan No. Aafcp9383D (Appellant) (Respondent)

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

ITA 4940/DEL/2019[2014-15]Status: DisposedITAT Delhi12 Jul 2022AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

Section 133ASection 194CSection 196Section 271Section 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. 3 ITA No. 4940 & Ors. T.S.Realtech P. Ltd. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

ITA 4941/DEL/2019[2015-16]Status: DisposedITAT Delhi12 Jul 2022AY 2015-16

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

Section 133ASection 194CSection 196Section 271Section 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. 3 ITA No. 4940 & Ors. T.S.Realtech P. Ltd. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

ITA 4942/DEL/2019[2017-18]Status: DisposedITAT Delhi12 Jul 2022AY 2017-18

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

Section 133ASection 194CSection 196Section 271Section 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. 3 ITA No. 4940 & Ors. T.S.Realtech P. Ltd. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee

PIVOTAL INFRASTRUCTURE LTD,GURGAON vs. ADDI. CIT SPL. RANGE 76, NEW DELHI

The appeal are allowed

ITA 6261/DEL/2019[2014-15]Status: DisposedITAT Delhi14 Jul 2022AY 2014-15

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharmaita No. 6261/Del/2019, A.Y. 2014-15

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

ITA 6734/DEL/2019[2014-15]Status: DisposedITAT Delhi06 Jul 2022AY 2014-15

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

ITA 6736/DEL/2019[2017-18]Status: DisposedITAT Delhi06 Jul 2022AY 2017-18

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

ITA 6735/DEL/2019[2016-17]Status: DisposedITAT Delhi06 Jul 2022AY 2016-17

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

TDI INFRASTRUCTURE LTD.,NEW DELHI vs. ADDI. CIT RANGE-76, NEW DELHI

The appeals are allowed

ITA 6653/DEL/2019[2014-15]Status: DisposedITAT Delhi06 Jul 2022AY 2014-15

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmatdi Infrastructure Ltd. Vs. Addl. Cit, 10, Shaheed Bhagat Singh Marg, Range-76, Connaught Place, New Delhi New Delhi- 110001 Pan : Aaaci5799P (Appellant) (Respondent)

Section 133ASection 194CSection 271C

271C was initiated. In response, the assessee filed stating that provisions of section 194C. were not applicable on payment, of EDC because the payment was made to the Government and not to the HUDA. The Ld. Ld. AO examined the submission of assessee and mentioned that in the present case, the assessee has paid EDC to HUDA for carrying

ITO WARD-77(3), NEW DELHI vs. STERLING INFRASTRUCTURE PVT. LTD., NEW DELHI

In the result, appeal filed by the Revenue/Department stands dismissed

ITA 1236/DEL/2023[2014-15]Status: DisposedITAT Delhi22 Nov 2023AY 2014-15

Bench: Shri Shamim Yahya & Shri Kul Bharatassessment Year: 2014-15

Section 133ASection 194Section 201Section 201(1)Section 271C

transfers land to private builders who has to pay user fee for the developed urban infrastructure which is named as EDC under the license to set up commercial set ups. EDC would be called rent ...any other agreement or arrangement for the use of (either separately or together) any,-(a) land; or Therefore EDC ought to be subjected

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3382/DEL/2018[2016-17]Status: DisposedITAT Delhi05 May 2022AY 2016-17

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3383/DEL/2018[2017-18]Status: DisposedITAT Delhi05 May 2022AY 2017-18

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3377/DEL/2018[2011-12]Status: DisposedITAT Delhi05 May 2022AY 2011-12

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3378/DEL/2018[2012-13]Status: DisposedITAT Delhi05 May 2022AY 2012-13

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3379/DEL/2018[2013-14]Status: DisposedITAT Delhi05 May 2022AY 2013-14

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3380/DEL/2018[2014-15]Status: DisposedITAT Delhi05 May 2022AY 2014-15

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

271C separately against the assessee for failure to deduct tax at source for the A.Ys. 2010-11 to 2017-18. 4. In appeal, the Ld. CIT(A) upheld the action of the A.O. by observing as under : “4.13. I have considered the submission of the appellant, perused the assessment order, remand report and rejoinder of the appellant. The assessing officer