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17 results for “transfer pricing”+ Section 44Bclear

Sorted by relevance

Delhi17Dehradun6Mumbai4Lucknow1Jaipur1Chandigarh1Jodhpur1

Key Topics

Section 143(3)29Section 153A28Disallowance15Addition to Income15Natural Justice15Section 26310Permanent Establishment2Double Taxation/DTAA2

TATA NYK SHIPPING PTE. LTD. ,SINGAPORE vs. CIT INTERNATIONAL TAXATION-3, NEW DELHI

In the result, the appeal is allowed

ITA 1067/DEL/2022[2016-17]Status: DisposedITAT Delhi09 Mar 2023AY 2016-17

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2016-17 M/S. Tata Nyk Shipping Pte. Vs. Commissioner Of Income Tax, Ltd., International Taxation-3, 6, Shenton Way, #18-08B, New Delhi Oue Downtown 2, Singapore Pan :Aadct9945P (Appellant) (Respondent)

Section 142(1)Section 263Section 92C

Transfer Pricing Officer (TPO) to examine arm’s 3 AY: 2016-17 length nature of such transactions. After considering the order of the TPO passed under section 92CA(3) of the Act, the Assessing Officer ultimately completed the assessment vide order dated 14.06.2019 accepting the income declared by the assessee. The assessment order so passed was taken up for review

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

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

ITA 930/DEL/2020[2016-17]Status: DisposedITAT Delhi04 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

Section 115JSection 143(3)Section 250

44B or section 44BB or section 44BBA or section 44BBB and such income has been offered to tax at the rates specified in those sections. Explanation 5.—For the purposes of sub-section (2), the expression "securities" shall have the same meaning as assigned to it in clause (h) of section 2 of the Securities Contracts (Regulation

SHENHZHEN SDG INFORMATION CO. LTD.,DELHI vs. CIRCLE INT. TAXATION 3(1)(2), DELHI

Appeal is allowed

ITA 746/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Commissioner Of Income Tax, Shenhzhen Sdg Information Co. Ltd., International Taxation-3, C/O- Tass Advisors Llp, 62, New Delhi Lower Ground Floor, Pocket 2, Jasola, New Delhi Pan: Aavcs7426C (Appellant) (Respondent) Assessee By Sh. Divyanshu Agrawal, Adv. Sh. Anubhav Rastogi, Adv. Department By Sh. Vijay B Vasanta, Cit(Dr) Date Of Hearing 10.03.2025 Date Of Pronouncement 05.06.2025 Order

Section 263Section 44B

transfer pricing analysis. 8.6.2 Indian DTAAs follow relevant business activity approach to attribute profit to the PE. Under this approach, the arm's length profit would be what the independent party performing same of similar business activities under same or similar condition would earn. In a simpler term, it refers to the arm's length profit of the business activity

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1199/DEL/2020[2013-14]Status: DisposedITAT Delhi09 May 2022AY 2013-14

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1200/DEL/2020[2014-15]Status: DisposedITAT Delhi09 May 2022AY 2014-15

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1201/DEL/2020[2015-16]Status: DisposedITAT Delhi09 May 2022AY 2015-16

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1202/DEL/2020[2016-17]Status: DisposedITAT Delhi09 May 2022AY 2016-17

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1338/DEL/2020[2010-11]Status: DisposedITAT Delhi09 May 2022AY 2010-11

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1196/DEL/2020[2010-11]Status: DisposedITAT Delhi09 May 2022AY 2010-11

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1340/DEL/2020[2012-13]Status: DisposedITAT Delhi09 May 2022AY 2012-13

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1341/DEL/2020[2013-14]Status: DisposedITAT Delhi09 May 2022AY 2013-14

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1342/DEL/2020[2014-15]Status: DisposedITAT Delhi09 May 2022AY 2014-15

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1343/DEL/2020[2015-16]Status: DisposedITAT Delhi09 May 2022AY 2015-16

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1344/DEL/2020[2016-17]Status: DisposedITAT Delhi09 May 2022AY 2016-17

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1339/DEL/2020[2011-12]Status: DisposedITAT Delhi09 May 2022AY 2011-12

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1197/DEL/2020[2011-12]Status: DisposedITAT Delhi09 May 2022AY 2011-12

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 1198/DEL/2020[2012-13]Status: DisposedITAT Delhi09 May 2022AY 2012-13

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Ms. Meenakshi J. Goswami, CIT DR
Section 143(3)Section 153A

44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers. 50. The assessing