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73 results for “transfer pricing”+ Section 69Bclear

Sorted by relevance

Delhi73Jaipur51Chandigarh22Bangalore20Mumbai18Agra14Amritsar11Chennai11Cochin7Indore5Surat4Ahmedabad4Jodhpur2Hyderabad1Pune1Raipur1Rajkot1Allahabad1

Key Topics

Section 153A100Addition to Income70Disallowance46Section 69B39Unexplained Investment35Bogus Purchases33Section 14A20Section 6818Section 69C18Section 143(3)

CIT vs. DINESH JAIN HUF

ITA - 610 / 2012HC Delhi19 Oct 2012
Section 132Section 153ASection 260ASection 69B

Section 69B on the ground that there was no evidence to show any understatement or suppression of the sale consideration/purchase consideration and therefore, no addition can be made on the basis of the estimated market value of the properties. The Tribunal held as follows : “21. We have heard both the parties and gone through the material available on record

ACIT, CC-14, DELHI vs. MAYFAIR RESORTS INDIA LTD., NEW DELHI

In the result, the appeal of the revenue is dismissed

ITA 2008/DEL/2021[2010-11]Status: DisposedITAT Delhi17 Aug 2023AY 2010-11

Showing 1–20 of 73 · Page 1 of 4

12
Section 13212
Search & Seizure12
For Appellant: Shri Yudhister Mehtani, CA
For Respondent: Shri Subhra Jyoti Chakraborty, CIT(DR)
Section 292CSection 69Section 69A

price paid for the property; (d) Section 69B does not permit an inference to be drawn from the circumstances surrounding the transaction that the purchaser of the property must have paid more than what was actually recorded in this books of account, because such an inference could be very subjective and could lead to the taxation of notional or fictitious

ACIT, CC-15, NEW DELHI vs. YASH PAL MENDIRATTA, DELHI

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1863/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

price paid for the property; (d) Section 69B does not permit an inference to be drawn from the circumstances surrounding the transaction that the purchaser of the property must have paid more than what was actually recorded in this books of account, because such an inference could be very subjective and could lead to the taxation of notional or fictitious

ACIT, CIRCLE CC 15, NEW DELHI vs. ALKA MENDIRATTA , DELHI

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1864/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

price paid for the property; (d) Section 69B does not permit an inference to be drawn from the circumstances surrounding the transaction that the purchaser of the property must have paid more than what was actually recorded in this books of account, because such an inference could be very subjective and could lead to the taxation of notional or fictitious

COMMISSIONER OF INCOME TAX vs. M/S ASSOCIATE TECHNO PLASTICS P. LTD

The appeal is dismissed and the question of law is answered in favour of the

ITA/20/2000HC Delhi21 Nov 2013
Section 143(1)(a)Section 148Section 69B

transferred 12,70,000 shares of HCL to 62 different persons at prices varying between Rs.18.91 to Rs.6.02, between May, 1988 to November, 1988. The Assessing Officer taking into consideration the market price on different dates when the sale transactions were entered 2013:DHC:6002-DB ITA Nos. 20/2000 & 95/2002 Page 4 of 28 into and made an addition

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

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 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

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

ITO, NEW DELHI vs. SMT. SUDHARSHNA ARORA, NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 1185/DEL/2010[2004-05]Status: DisposedITAT Delhi13 Mar 2026AY 2004-05

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarita No.1185 /Del./2010, A.Y. 2004-05 Ito, Vs Smt. Sudharshna Arora Ward-24(4), . B-6/9, Vasant Vihar, New Delhi New Delhi Pan: Aaepa8154H (Appellant) (Respondent)

Section 143(1)Section 143(2)

transferred shares to M/s SJS Holdings Ltd. for inadequate consideration. Initially, he estimated the price of per sq.yard of land at Rs. 5000/- on adhoc basis. Later on, the matter was referred to the valuation cell for valuation of land. The valuation cell has valued the price of land at Rs. 8000/- per sq.yard. The A.O. applied

BIMLA,DELHI vs. ITO WARD-38(5), NEW DELHI

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

ITA 7973/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Nov 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekbimla, Vs. Ito, Ward 38 (5), H.No.143, Village Hamidpur, New Delhi. Delhi – 110 036. (Pan : Bpdpb9344B) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Shri Ankit Kumar, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.09.2024 Date Of Order : 26.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-13, New Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 23.07.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Filed Return Of Income Declaring Total Income Of Rs.2,23,030/- On 14.08.2014. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Through Cass & Notices

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 131Section 143Section 143(2)Section 69

price. In this regard, he brought to our notice pages 116 to 119 of the paper book. He submitted that section 56(2)(vii)(b)(ii) of the Act was amended to provide sub-clause (ii) of the Finance Act, 2013 w.e.f. 01.04.2014. He brought to 8 our notice the extracts from the Memorandum of Finance Bill reported

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, NEW DELHI, NEW DELHI vs. NEELAM ARYA, DELHI

The appeal of the Revenue is dismissed

ITA 1533/DEL/2024[2010-11]Status: DisposedITAT Delhi30 May 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Naveen Chandradcit, Central Circle -25, Vs. Neelam Arya Room No. 317, 3Rd Floor, 7, Neelanchal, Bandh E-2, Ara Centre, Road,Chandanhulla, Jhandewalan Extension Chattarpur, New Delhi – 110055 Delhi – 110074 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adtpa6583A Appellant .. Respondent

For Appellant: Sh. Sanjeev Kaushal, CIT, DRFor Respondent: Sh. Salil Aggarwal, Sr. Adv. &
Section 115BSection 127Section 132Section 142(1)Section 143(2)Section 153ASection 69B

transferred from Circle 13(1), New Delhi to Central Circle – 25, New Delhi and notice under Section 153A of the Act dated 05.08.2019 was issued upon the assessee asking him to file a return of income within 15 days from the date of receipt of the said notice. The return of income was filed on 03.10.2019 declaring income at Rs.43

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

In the result, the appeal of the Revenue is dismissed

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17
Section 11Section 12ASection 143(3)

69B), Unexplained Expenditure, etc. (Section 69C). The\nrequirement of each of the aforesaid sections are different and the rules of\nevidence and burden of proof are also different, hence, unless the\nPetitioner to put the notice as to the exact contravention or provisions of\nlaw under which assessment or additions are sought to be made, the\nPetitioner cannot defend

COMMISSIONER OF INCOME TAX vs. DINESH KUMAR AGARWAL

ITA/411/2010HC Delhi29 Aug 2013
Section 69B

transfer at Rs.3,30,24,000/-. The Assessing Officer, however, felt that the report of the DVO requires moderation after noticing the fact that the property was leasehold and 36 years out of 99 years of lease were over. He also referred to the fact that the lease deed postulated payment of 50% unearned increase and determined the value

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

M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

ITA 4971/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Aug 2022AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

price at which the conversion of investment took place wouldbe chargeable under the head income from business. Since, the conversion and subsequent sale have taken place during the same previous year, the sale proceeds become taxable under the head capital gain, unless the appellant has adopted different rates for conversion & subsequent transfers. 4.5.5 However as pointed

M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

ITA 4972/DEL/2015[2012-13]Status: DisposedITAT Delhi25 Aug 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

price at which the conversion of investment took place wouldbe chargeable under the head income from business. Since, the conversion and subsequent sale have taken place during the same previous year, the sale proceeds become taxable under the head capital gain, unless the appellant has adopted different rates for conversion & subsequent transfers. 4.5.5 However as pointed