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82 results for “transfer pricing”+ Section 50C(1)clear

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Key Topics

Section 153A60Addition to Income59Section 143(3)41Section 50C37Section 14825Section 14716Section 143(1)11Section 43C11Reassessment10

YOGESH JUNEJA,FARIDABAD vs. ACIT, CIRCLE-29(1), NEW DELHI

In the result, the Appeal filed by the assessee is allowed

ITA 218/DEL/2020[2015-16]Status: DisposedITAT Delhi18 Oct 2022AY 2015-16

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar Usi.T.A. No. 218/Del/2020 (A.Y 2015-16)

Section 143(3)Section 154

Section 50C (1) of the Act the parties in many times faced undue hardship and difficulties when agreement to sell of a property was executed in earlier years and transferred took place in later years. During the intervening period price

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2844/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024

Showing 1–20 of 82 · Page 1 of 5

Natural Justice10
Section 2509
Deduction9
AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2635/DEL/2022[2020-21]Status: DisposedITAT Delhi02 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2632/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2845/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2633/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2846/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2634/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

50C by the Finance Act, 2018, w.e.f. 1-4- 2019 : Provided also that where the value adopted or assessed or assessable by the stamp valuation authority does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer, the consideration so received or accruing as a result of the transfer shall

DCIT, CIRCLE - 19(1), NEW DELHI vs. RAPID ENGINEERING COMPANY PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3522/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Dy. C.I.T Vs. Rapid Engineering Co. Pvt Ltd Circle – 19(1) 111-112, Dsidc Sheds Delhi Okhla Phase – 1, New Delhi

For Appellant: Shri Sumit Bansal, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR
Section 143(3)Section 50(1)Section 50C(1)Section 56(2)(x)

transfer of immovable property". Section 50C, thus, on a conceptual note, is a provision to address capital gains tax evasion on account of understatement of the consideration. Of course, the law provides, under section 50C(2), that wherever an assessee claims that the actual market rate is less than the stamp duty valuation, he can have the matter referred

AKASH GARG,NEW DELHI vs. DCIT,CIRCLE INT. TAX 1(3)(1), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 313/DEL/2023[2018-19]Status: DisposedITAT Delhi04 Dec 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadi.T.A No.313/Del/2023 िनधा"रणवष"/Assessment Year: 2018-19 बनाम Akash Garg Dcit 4/71, Road No.71, Vs. Circle Int. Tax Punjabi Bagh West, 1(3)(1), New Delhi. New Delhi. Pan No. Aldpg7446A अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 48Section 50C

price of the land, as valued by the assessee, was more than the value adopted by the stamp valuation authority. Section 50C of the Act is a special provision for full value of consideration in some cases. Sub- section (1) of section 50C of the Act provides that where the consideration received or accruing as a result of the transfer

GURBAKSHISH SINGH BATRA,NEW DELHI vs. PR. CIT - 12, NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 396/DEL/2021[2016-17]Status: DisposedITAT Delhi31 Mar 2022AY 2016-17

Bench: Shri R.K. Panda & Shri N.K. Choudhryassessment Year: 2016-17 Gurbakshish Singh Batra, Vs Pr.Cit-12, E-1511, Wazir Nagr, New Delhi. Kotla Mubarakpur, New Delhi. Pan: Adspb2480J (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi, Ca Revenue By : Shri Shashi Bhushan Sukla, Cit, Dr Date Of Hearing : 15.02.2022 Date Of Pronouncement : 31.03.2022 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22Nd March, 2021 Of The Pcit, Delhi-12, Passed U/S 263 Of The It Act For The Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Filed His Return Of Income On 6Th October, 2016 Declaring The Total Income At Rs.44,86,160/-. The Return Was Processed U/S 143(1) Of The It Act. Subsequently, The Case Of The Assessee Was Selected For ‘Limited Scrutiny’ Based On The Following Reasons:-

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Shri Shashi Bhushan Sukla, CIT, DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 244ASection 263Section 50C

transfer of leasehold rights. 3.2 In any case, this being a case of bonafide sale made in accordance with prevailing market rate, the Pr. CIT, New Delhi was not justified in disputing the sale consideration u/s 50C without appreciating the factual position or making any reference to the Valuation Officer in terms of provisions of section 55A of the Income

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

ITA 704/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

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

ITA 2587/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

ITA 4328/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

ITA 927/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

SANDEEP HOODA,NEW DELHI vs. PR.CIT - 7, NEW DELHI

The appeal is allowed and the impugned order dated 30

ITA 397/DEL/2021[2015-16]Status: DisposedITAT Delhi10 Aug 2022AY 2015-16

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmasandeep Hooda, Vs. Pr. Cit-7, C/O. Rra Taxindia, D-28, South New Delhi Extension, Part-I, New Delhi (Appellant) (Respondent) Pan: Aacph5453J

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 143(3)Section 263Section 27Section 48Section 50Section 500(1)Section 50CSection 50C(2)Section 50c(2)

transfer. Further as per Section 50C(2) of the Income Tax Act, a reference to DVO is required in case an assessee contests the circle rate to be higher than the fair market value of the relevant capital asset. Since Assessing Officer neither assessed the value at the circle rate a;- mandated u/s 50 C (1), nor referred

VIJAY KUMAR ,MEERUT vs. DCIT,CC, GZBD

In the result, both appeals of the different assessees are allowed

ITA 26/DEL/2022[2017-18]Status: DisposedITAT Delhi11 May 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2017-18]

Section 14Section 234ASection 271ASection 56(2)(vii)

50C(2) Without prejudice to the provisions of sub-section (1), where— (a) the assessee claims before any Assessing Officer that the value adopted or assessed or assessable by the stamp valuation authority under sub-section (1) exceeds the fair market value of the property as on the date of transfer; (b) the value so adopted or assessed or assessable

VINIT KUMAR ,MEERUT vs. DCIT,CC, GHAZIABAD

In the result, both appeals of the different assessees are allowed

ITA 24/DEL/2022[2017-18]Status: DisposedITAT Delhi11 May 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2017-18]

Section 14Section 234ASection 271ASection 56(2)(vii)

50C(2) Without prejudice to the provisions of sub-section (1), where— (a) the assessee claims before any Assessing Officer that the value adopted or assessed or assessable by the stamp valuation authority under sub-section (1) exceeds the fair market value of the property as on the date of transfer; (b) the value so adopted or assessed or assessable

SIGMA PARADISE,GHAZIABAD vs. DCIT, WARD 2(2)(1), GHAZIABAD

The appeal is allowed

ITA 823/DEL/2024[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2013-14 Sigma Paradise, Vs Dcit, Km-78, Kavi Nagar, Ward 2(2)(1), Ghaziabad, Ghaziabad. Uttar Pradesh – 201 002. Pan:Aazfs9643L (Appellants) (Respondents) Assessee By : Shri Rajiv Khandelwal, Ca; & Shri Gagan R. Khandelwal & Shri Jaind Kumar Jaiswal, Advocates Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 18.09.2025 Date Of Pronouncement : 26.11.2025

For Appellant: Shri Rajiv Khandelwal, CA; &For Respondent: Shri Manish Gupta, Sr. DR
Section 11Section 143(3)Section 147Section 148Section 4Section 50CSection 6

price for calculation of capital Gain and also further request to please not invoke Section 50C of IT Act. ” 4. The AO was not satisfied and invoked section 50C of the Act and concluded as follows: “9. In light of the above discussion and owing to no substantial explanation from the assesse with respect to the addition proposed, this office

SH. RAJESH KAKKAR,KARNAL vs. PR. CIT, KARNAL

The appeal is allowed

ITA 823/DEL/2016[2011-12]Status: DisposedITAT Delhi16 Apr 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2013-14 Sigma Paradise, Vs Dcit, Km-78, Kavi Nagar, Ward 2(2)(1), Ghaziabad, Ghaziabad. Uttar Pradesh – 201 002. Pan:Aazfs9643L (Appellants) (Respondents) Assessee By : Shri Rajiv Khandelwal, Ca; & Shri Gagan R. Khandelwal & Shri Jaind Kumar Jaiswal, Advocates Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 18.09.2025 Date Of Pronouncement : 26.11.2025

For Appellant: Shri Rajiv Khandelwal, CA; &For Respondent: Shri Manish Gupta, Sr. DR
Section 11Section 143(3)Section 147Section 148Section 4Section 50CSection 6

price for calculation of capital Gain and also further request to please not invoke Section 50C of IT Act. ” 4. The AO was not satisfied and invoked section 50C of the Act and concluded as follows: “9. In light of the above discussion and owing to no substantial explanation from the assesse with respect to the addition proposed, this office