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910 results for “transfer pricing”+ Section 56(2)(x)clear

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Key Topics

Section 143(3)67Addition to Income54Section 153A47Section 92C33Transfer Pricing27Section 144C25Disallowance22Deduction21Comparables/TP20

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

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

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18
Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

section 56(2)(viib). It is evidenced, during the appellate proceedings, by the\nfact that M/s. Otter Ltd has immediately sold certain no of shares to an India\nbased Indian resident entity. M/s. Link Investment Trust. It is clearly evident\nthat if M/s. Link Investment Trust had bought the shares of the appellant-\ncompany at such a huge premium

THE PR. COMMISSIONER OF INCOME TAX-4 vs. GE MONEY FINANCIAL SERVICES PVT. LTD.

ITA/224/2017HC Delhi10 Apr 2017

Showing 1–20 of 910 · Page 1 of 46

...
Section 14317
Section 80I13
Section 14811

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 10A(2)(c)

Section 2(iii) approval in view of the interim order dated 10th January, 2017 of the Division Bench of this Court. However, this does not, in any manner, confer any right upon the petitioner. Similarly, the communication dated 20th October, 2016 issued by the Ministry of Mines does not come to the aid of the petitioner. By the said communication

MEENU SATIJA,NEW DELHI vs. PR. CIT (CENTRAL), GURGAON

In the result appeal filed by the assessee stands allowed

ITA 3215/DEL/2016[2010-11]Status: DisposedITAT Delhi27 Jan 2017AY 2010-11

Bench: Shri J. S. Reddy & Smt. Beena A. Pillai

For Appellant: Sh. R. S. Ahuja, CAFor Respondent: Smt. Rachna Singh, CIT DR
Section 132(1)Section 133Section 143(2)Section 153A(1)(a)Section 153A(1)(b)Section 263Section 56(2)(vii)

x 7,76,785). Accordingly, the difference of fair market value of the bonus/ right equity shares and the value at which these shares were allotted to the assessee by M/s Bestech India Pvt. Ltd., comes to Rs. 1,61,05,074/- (Rs. 1,75,78,644 -Rs.14,73,570). Therefore, amount of Rs. 1,61,05,0747- needs

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

VIJAY AGGARWAL,DELHI vs. ITO, WARD- 48(5), NEW DELHI

In the result, all the appeals of different assessees are partly allowed

ITA 1077/DEL/2019[2010-11]Status: DisposedITAT Delhi30 May 2019AY 2010-11

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahuassessment Year: 2010-11

Section 147Section 148Section 56(2)(vii)Section 68

price as claimed by the purchaser assessee-company. The Assessing Officer had not been able to establish that anything more than what had been admitted to have been paid and received had passed hands in order to invoke provisions of section 69B. As nothing had been proved to show that any other amount than admitted had been paid

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

ITA 5546/DEL/2011[2005-06]Status: DisposedITAT Delhi21 Dec 2020AY 2005-06

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Vipul Kashyap, Sr.D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 17(2)(iii)Section 2(24)(iv)Section 234B

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

ITA 5512/DEL/2011[2005-06]Status: DisposedITAT Delhi21 Dec 2020AY 2005-06

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Vipul Kashyap, Sr.D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 17(2)(iii)Section 2(24)(iv)Section 234B

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

ITA 5513/DEL/2011[2005-06]Status: DisposedITAT Delhi21 Dec 2020AY 2005-06

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Vipul Kashyap, Sr.D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 17(2)(iii)Section 2(24)(iv)Section 234B

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. KRISHNA KUMAR PANT,NEW DELHI vs. DCIT, NEW DELHI

ITA 5574/DEL/2011[2005-06]Status: DisposedITAT Delhi21 Dec 2020AY 2005-06

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

For Appellant: Shri Tarandeep Singh, CAFor Respondent: Shri Vipul Kashyap, Sr.D.R
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 17(2)(iii)Section 2(24)(iv)Section 234B

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

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

x. The learned authorised representative also placed heavy reliance on the direction of the learned dispute resolution panel in case of a sister concern SRF Ltd which is also placed in the paper book stating that in the identical facts and circumstances of the case the learned dispute resolution panel has held that steam has a cost and therefore

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/710/2015HC Delhi11 Dec 2015
Section 260ASection 92C

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under Section 92B of the Income Tax Act, 1961? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/110/2014HC Delhi11 Dec 2015
Section 260ASection 92C

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under Section 92B of the Income Tax Act, 1961? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

ITA 3865/DEL/2014[2008-09]Status: DisposedITAT Delhi16 Jun 2020AY 2008-09

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 143(3)Section 14ASection 153Section 40Section 92C(2)

56,690/-by relying on the ITAT decision in the assessee's own case for the AY 2006-07, ignoring the fact that the revenue is in appeal. Thus, the issue has not attained its finality. 2. On the facts and circumstances of the case and in law, the Ld.CIT (A) has erred in reducing the disallowance of software expenses