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166 results for “transfer pricing”+ Section 50C(3)clear

Sorted by relevance

Mumbai279Delhi166Ahmedabad59Hyderabad55Pune54Jaipur46Chennai42Kolkata37Bangalore34Indore28Nagpur21Surat16Chandigarh14Rajkot10Lucknow10Raipur8Visakhapatnam6Amritsar4Karnataka4Jabalpur4Agra3Jodhpur2Ranchi2Cuttack2Calcutta1Guwahati1Varanasi1Allahabad1Telangana1Patna1Cochin1

Key Topics

Addition to Income64Section 50C59Section 143(3)48Section 153A45Section 14829Section 14719Section 26317Capital Gains16Section 92C12

DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

ITA 7362/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Oct 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Pradeep Dinodia, C. A.; &For Respondent: Shri Surendra Pal [CIT] – DR
Section 133(6)Section 143Section 143(3)Section 144Section 92C

3 of the appeal and direct the learned transfer-pricing officer to delete the addition of ₹ 1,035,745,275 which was made determining the arm’s-length price of transfer of steam from eligible unit to non-eligible unit by considering the cost of production of the steam at Rs. Nil. 48. The ground number 4 is with respect

Showing 1–20 of 166 · Page 1 of 9

...
Section 43C12
Disallowance10
Natural Justice10

DHARA SINGH,GHAZIABAD vs. ITO, WARD-1(2), GHAZIABAD

In the result, the Appeal filed by the Assessee stands allowed

ITA 2213/DEL/2018[2012-13]Status: DisposedITAT Delhi20 Jul 2018AY 2012-13

Bench: Shri H.S. Sidhu & Shri T.S. Kapooray: 2012-13 Dhara Singh Ito, Ward 1(2), C/O Rupinder Kumar Vs. Ghaziabad Aggarwal, Uttar Pradesh Advocate, Ab-1A/22, Sector-51, Noida -201301 (Pan: Czjps0155A) (Assessee) (Respondent)

For Appellant: Sh. Gautam Jain, Adv., ShFor Respondent: Sh. V.K. Jiwani, Sr. DR
Section 144Section 147Section 148Section 234BSection 234CSection 48Section 50CSection 54F

50C received, it is noticed that Sh. Dhara Singh has sold immovable property, the details of transfer of capital assets is as under:- Descripti Transfer Market Difference on of (Sale Value property Price) Khasra 3,73,01,0 5,78,00,0 2,04,99,0 No. 1135 00 00 00 As can be seen from the above immovable property

UMA DUTT PALIWAL PROP.,PANIPAT vs. ADDL. CIT, PANIPAT

In the result appeal of the assessee is allowed

ITA 4626/DEL/2011[2008-09]Status: DisposedITAT Delhi23 Feb 2016AY 2008-09

Bench: Shri J. Sudhakar Reddy & Sh. Sudhanshu Srivastavaay: 2008-09 Uma Dutt Paliwal, Vs Addl. Cit, Prop. Paliwal Home Furnishing, Karnal. Panipat. (Appellant) (Respondent) Appellant By: Shri Gurjeet Singh, Ca Respondent By: Shri O.P.Meena, Sr. Dr

For Appellant: Shri Gurjeet Singh, CAFor Respondent: Shri O.P.Meena, Sr. DR
Section 36(1)(iii)Section 50C

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed if it were referred to such authority for the purposes of the payment of stamp duty. (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7112/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2019AY 2013-14

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

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

ITA 4913/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

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

ITA 5026/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 1944/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2019AY 2012-13

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 1308/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Nov 2019AY 2010-11

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7637/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2019AY 2014-15

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

3 & 3.1 raised by the assessee are allowed as indicated. 64. Now, coming to Ground of appeal Nos. 4 to 4.2 wherein the issue raised is against the disallowance of expenses totaling to Rs.60,51,351/-, while computing the income from long term capital gains on sale of land, on the ground that the same were not incidental to sale

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

price is higher can be drawn, if the circumstances spelt out in Section 50-C are fulfilled. This provision was challenged before the Madras High Court, in K.R. Palanisamy (supra). The Court repelled the challenge, but nevertheless held that: "Sub-sections (2) and (3) of Section 50C provides further safeguard to the assessee, in the sense that if the assessee

NARENDRA KUMAR SINGH,NEW DELHI vs. ACIT, CENTRAQL CIRCLE-15, , NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 12/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Apr 2019AY 2013-14

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2013-14 Shri Narendra Kumar Singh, Vs. Asstt. Commissioner Of C/O- Vivek Bansal, 2Nd Floor, Income Tax, B-3/4, Safdarjung Enclave, Central Circle-15, New Delhi New Delhi Pan :Akmps8087M (Appellant) (Respondent) Appellant By S/Shri I.P. Bansal & Vivek Bansal, Advocates Respondent By Smt. Rinku Singh, Sr.Dr

Section 143(2)Section 143(3)Section 234BSection 50CSection 50C(1)Section 50C(2)(a)

3. In this regard it may be mentioned that provision of Section 50C(1) is mandatory whereby there is no option to the Assessing Officer but 7 to adopt the valuation done by the SVA in place of apparent consideration shown by the assessee. It has been held that where there was material on record that valuation done

ANALJIT SINGH,DELHI vs. DCIT, CIRCLE- 16(2), DELHI

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

ITA 4737/DEL/2017[2014-15]Status: DisposedITAT Delhi01 Dec 2017AY 2014-15

Bench: Shri Amit Shukla & Shri O.P.Kant

Section 143(3)Section 2Section 50D

50C of the Act was already on the statute prior to the former section being incorporated in the Act. If section 50D of the Act was sufficient to capture the situation as in the present case, then there was no necessity to insert provision of Section 50CA of the Act in the statute by the Finance Act, 2017 w.e.f

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

transfer of steam has taken though additional grounds\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 42 \nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission

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

transfer of steam has taken though additional grounds\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 42\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission

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

transfer of steam has taken though additional grounds\n\nPage | 42\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission of additional\nevidences

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

transfer of steam has taken though additional grounds\n\nPage | 42\n\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds

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

price to the Lessor. He drew the attention of the Bench to the relevant portion of the Lease Deed which reads as under: “5(a) The Lease shall not sell, transfer, assign or otherwise part with the possession of the whole or any part of the industrial plot except with the previous consent in writing of the Lessor which

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

price (i.e. Rs.1,04,17,400/-) and ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. the stamp duty value (i.e. Rs. 3,40,16,000/-) of the property by invoking the provision of section 50C. 77. Aggrieved by the order passed by the AO, the assessee company preferred an appeal before the ld. CIT(A). 78. During the course

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 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

price (i.e. Rs.1,04,17,400/-) and ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. the stamp duty value (i.e. Rs. 3,40,16,000/-) of the property by invoking the provision of section 50C. 77. Aggrieved by the order passed by the AO, the assessee company preferred an appeal before the ld. CIT(A). 78. During the course

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

price (i.e. Rs.1,04,17,400/-) and ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. the stamp duty value (i.e. Rs. 3,40,16,000/-) of the property by invoking the provision of section 50C. 77. Aggrieved by the order passed by the AO, the assessee company preferred an appeal before the ld. CIT(A). 78. During the course