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30 results for “transfer pricing”+ Section 271Cclear

Sorted by relevance

Mumbai32Delhi30Bangalore6Kolkata5Ahmedabad4Visakhapatnam3Jaipur1Pune1SC1Telangana1Varanasi1

Key Topics

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

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 30 · Page 1 of 2

7
Section 1957
Deduction7

PERNOD RICARD INDIA PVT. LTD,GURGAON vs. DCIT, CENTRAL CIRCLE- 31, NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1365/DEL/2018[2012-13]Status: DisposedITAT Delhi15 May 2020AY 2012-13

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: H.K. Choudhary, CIT, DR
Section 92C

Transfer Pricing Adjustment on account of AMP adjustment and separate disallowance under section 40(a)(ia) of the Act, has resulted in a double disallowance. Re: Consequential Grounds 30. That the Ld. AO erred in initiating penalty proceedings under section 271(l)(c) of the Act. ITA No.1365,1379/Del/2018 & 2366/Del/2019 31. That the Ld. AO erred in initiating penalty proceedings

DCIT, CC-31, NEW DELHI vs. PERNOD RICARD INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2601/DEL/2019[2014-15]Status: DisposedITAT Delhi15 May 2020AY 2014-15

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: H.K. Choudhary, CIT, DR
Section 92C

Transfer Pricing Adjustment on account of AMP adjustment and separate disallowance under section 40(a)(ia) of the Act, has resulted in a double disallowance. Re: Consequential Grounds 30. That the Ld. AO erred in initiating penalty proceedings under section 271(l)(c) of the Act. ITA No.1365,1379/Del/2018 & 2366/Del/2019 31. That the Ld. AO erred in initiating penalty proceedings

ACIT, CC- 31, NEW DELHI vs. PERNOD RICHARD INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1607/DEL/2018[2012-13]Status: DisposedITAT Delhi15 May 2020AY 2012-13

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: H.K. Choudhary, CIT, DR
Section 92C

Transfer Pricing Adjustment on account of AMP adjustment and separate disallowance under section 40(a)(ia) of the Act, has resulted in a double disallowance. Re: Consequential Grounds 30. That the Ld. AO erred in initiating penalty proceedings under section 271(l)(c) of the Act. ITA No.1365,1379/Del/2018 & 2366/Del/2019 31. That the Ld. AO erred in initiating penalty proceedings

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2366/DEL/2019[2014-15]Status: DisposedITAT Delhi15 May 2020AY 2014-15

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: H.K. Choudhary, CIT, DR
Section 92C

Transfer Pricing Adjustment on account of AMP adjustment and separate disallowance under section 40(a)(ia) of the Act, has resulted in a double disallowance. Re: Consequential Grounds 30. That the Ld. AO erred in initiating penalty proceedings under section 271(l)(c) of the Act. ITA No.1365,1379/Del/2018 & 2366/Del/2019 31. That the Ld. AO erred in initiating penalty proceedings

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

NOKIA INDIA SALES P.LTD,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE-6, , NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 7244/DEL/2017[2013-14]Status: DisposedITAT Delhi25 Oct 2021AY 2013-14

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7244/Del/2017 : Asstt. Year : 2012-13 Nokia India Sales Pvt. Ltd., Vs Addl. Cit, 807, New Delhi House, Special Range-6, Barakhamba Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaccn9141L Assessee By : Sh. Nageshwar Rao, Adv. Revenue By : Sh. Surenderpal, Cit Dr Date Of Hearing: 29.07.2021 Date Of Pronouncement: 25.10.2021

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Surenderpal, CIT DR
Section 133(6)Section 143(3)Section 194HSection 194JSection 40Section 9(1)(vii)

transfer pricing officer (“Ld. TPO”) erred in enhancing the income of the Appellant by Rs. 1,44,00,000/- by making a TP adjustment on account of AMP expenses incurred by the Appellant in the regular course of its business on the ground that it was excessive and should be compensated by the associated enterprises (“AE”). 5.1 That

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 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

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

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 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

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

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 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