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177 results for “transfer pricing”+ Section 69Aclear

Sorted by relevance

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Key Topics

Section 153A84Addition to Income74Section 153C59Disallowance31Bogus Purchases30Section 13229Section 69B27Unexplained Investment27Section 68

PICO DEEPALI OVERLAYS CONSORTIUM,HARYANA vs. DCIT CENTRAL CIRCLE 17, DELHI

In the result, both the captioned appeals filed by the assessee are allowed

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

TRANSFER PRICING ISSUES AFRESH IN LIGHT OF THE DIRECTIONS GIVEN BY THE ITAT VIDE ITS ORDER DATED 11.01.2021. TPO HAS ERRED IN PASSING THE SAME ORDER AS PASSED BY IT EARLIER BY ERRONEOUSLY CONSTRUING THE ITAT ORDER SETTING ASIDE THE ASSESSMENT FOR FRESH ADJUDICATION TO BE LIMITED TO THE ADDITIONS MADE UNDER SECTION 69A

PICO DEEPALI OVERLAYS CONSORTIUM (BY DEEPALI DESIGNS EXHIBITS (P.) LTD.),DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI

In the result, both the captioned appeals filed by the assessee are allowed

Showing 1–20 of 177 · Page 1 of 9

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23
Search & Seizure23
Section 69C22
Section 26318
ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

TRANSFER PRICING ISSUES AFRESH IN LIGHT OF THE DIRECTIONS GIVEN BY THE ITAT VIDE ITS ORDER DATED 11.01.2021. TPO HAS ERRED IN PASSING THE SAME ORDER AS PASSED BY IT EARLIER BY ERRONEOUSLY CONSTRUING THE ITAT ORDER SETTING ASIDE THE ASSESSMENT FOR FRESH ADJUDICATION TO BE LIMITED TO THE ADDITIONS MADE UNDER SECTION 69A

JATINDER PAL SINGH

ITA/16/2021HC Delhi08 Feb 2021
Section 130Section 132Section 132(4)Section 133(6)Section 202Section 260A

price. The Assessee has deposed that no agreement was signed, however Mr. Rahul Ahuja submitted a copy of MOU dated 12th April, 2010 and in this view of the matter, the statement of Mr. Rahul Ahuja was held to be unreliable. As rightly pointed out by Mr. Deepak Anand, it is indeed strange that the original MOU was not produced

AMARENDRA FINANCIAL PVT.LTD.,NEW DELHI vs. PR. CIT (CENTRAL) KNP , MEERUT

In the result, the appeal of the assessee is allowed

ITA 2526/DEL/2024[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17

Bench: the tribunal. Before us, assessee also take additional grounds of appeal which are admitted as they are purely legal in nature and requires no verification of facts by placing reliance on the judgment of hon'ble Supreme Court in the case of NTPC Ltd. reported in 229 ITR 383(SC).

Section 139(1)Section 153CSection 263Section 68

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2)No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3)Notwithstanding anything contained in sub-section

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 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

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 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

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

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

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

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

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

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

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 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

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

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

ACIT, CIRCLE-51(1), NEW DELHI vs. NAVEEN BATRA, NEW DELHI

In the result, the Cross Objection of the assessee is partly allowed

ITA 32/DEL/2020[2017-18]Status: DisposedITAT Delhi14 Aug 2024AY 2017-18

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Usassessment Year 2017-18

For Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR
Section 133ASection 143(3)

price. Nothing was brought to suggest that this was not a regular item of the stock dealt by the assessee. 7.6 In the case of Shri Lovishsinghal, Shri Vasu Singhal,ShriPramond Kumar Singhal and shrivinodkumarsinghal Vs. Income Tax Officer, Ward-2 and ACIT, Circle -Sriganganagar, Hon'ble ITAT JODHPUR Bench held that: “Surrender of income during survey - to be treated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1343/DEL/2024[2012-13]Status: DisposedITAT Delhi13 Sept 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1345/DEL/2024[2014-15]Status: DisposedITAT Delhi13 Sept 2024AY 2014-15

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1342/DEL/2024[2011-12]Status: DisposedITAT Delhi13 Sept 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1344/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Sept 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1346/DEL/2024[2015-16]Status: DisposedITAT Delhi13 Sept 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1347/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Sept 2024AY 2016-17

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

ITA 1348/DEL/2024[2018-19]Status: DisposedITAT Delhi13 Sept 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri M Balaganesh

For Appellant: Shri Vinod Kumar Bindal, ARFor Respondent: Shri Vijay B Vasanta, CIT-DR
Section 132Section 143(3)Section 144CSection 153ASection 153C

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

REENA KUMARI,NEW DELHI vs. ITO, NEW DELHI

The appeal of the assessee is allowed with consequences to follow

ITA 752/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Dec 2024AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2015-16 Reena Kumari, Vs Income Tax Officer, C-435, First Floor, Ward-54(4), Defence Colony, New Delhi. New Delhi – 110 024. Pan: Abcps0078F (Appellant) (Respondent) Assessee By : Shri R.S. Ahuja, Ca & Shri Pushpdeep Singh, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 26.11.2024 Date Of Pronouncement : 20.12.2024

For Appellant: Shri R.S. Ahuja, CA &For Respondent: Ms Harpreet Kaur Hansra, Sr. DR
Section 10(38)Section 131Section 143(3)Section 153(1)Section 68Section 69ASection 69C

69A. However, CIT (A), in Para 9.7 sustained addition u/s 68 only: Reena Kumari vs. ITO 5.1 As with regard to this issue we are of the considered view that there is no ambiguity which established the non-application of mind by the lower authorities and vitiates the additions made. Mentioning a wrong section by the AO is not fatal