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185 results for “transfer pricing”+ Section 69Cclear

Sorted by relevance

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Key Topics

Section 153A94Addition to Income84Section 153C54Section 69C45Disallowance41Bogus Purchases34Section 6832Section 69B26Unexplained Investment26Section 10(38)

ADD ADVISORS PRIVATE LIMITED,NEW DELHI vs. NATIONAL E-ASSESSMENT CENTRE, DELHI, DELHI

In the result, the appeal of the Revenue is dismissed and appeal

ITA 854/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2018-19 बनाम Deputy Commissioner Of Add Advisors Pvt. Ltd. Res-Cowork 03, 5Th Floor, Income Tax, Vs. Circle-1(1), Room No.153A, Caddie Commercial Tower, Aerocity, C.R. Building, I.P. Estate, Delhi International Airport, New Delhi. New Delhi. Pan No. Aaica3938N अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2018-19 बनाम Add Advisors Pvt. Ltd. Deputy Commissioner Of Res-Cowork 03, 5Th Floor, Vs. Income Tax, Caddie Commercial Tower, Aerocity, Circle-1(1), Room No.153A, Delhi International Airport, C.R. Building, I.P. Estate, New Delhi. New Delhi. Pan No. Aaica3938N अपीलाथ" Appellant ""यथ"/Respondent

Section 37(1)Section 69Section 69C

section 69C i.e. there must be an expenditure incurred and there should be failure of the assessee to explain the source of the expenditure to me satisfaction to the AO are not fulfilled, I believe the addition of Rs.3.75,0,000/- was not warranted. Accordingly, I direct the AO to delete the same. Ground no 3 is allowed

Showing 1–20 of 185 · Page 1 of 10

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Section 13219
Section 143(3)17

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

ITA 5356/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jan 2026AY 2021-22
Section 132Section 143(3)Section 144C(5)Section 148Section 153

transfer pricing adjustment particularly when all the requisite details & documents were placed before the authorities with regard to purchase of capital assets and hence, the entire erroneous addition needs to be deleted.\n13. That on the facts, law and in the circumstances of the case, the Ld. AO as well as the Ld. DRP has erred in law in making

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 as per the Agreement to Sell is Rs. 40.06 crores only and that the actual consideration which has got exchanged for purchase of the property was infact Rs. 40.06 crores as against Rs. 16 crores for which Sale Deed has been executed. 9. The Assessing Officer further held that one of the buyers Shri R. K. Chawla

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 as per the Agreement to Sell is Rs. 40.06 crores only and that the actual consideration which has got exchanged for purchase of the property was infact Rs. 40.06 crores as against Rs. 16 crores for which Sale Deed has been executed. 9. The Assessing Officer further held that one of the buyers Shri R. K. Chawla

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 prices. In second round, Ld. AO has merely said that there is no need to vitiate his earlier order since it has not been set aside. In fact, TPO in order dated 27.01.2021 page nos. 73 and 74 of paper books Volume I held that the issues are appearing in order of Ld. DRP regarding TP Report mentions TNMM

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

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 prices. In second round, Ld. AO has merely said that there is no need to vitiate his earlier order since it has not been set aside. In fact, TPO in order dated 27.01.2021 page nos. 73 and 74 of paper books Volume I held that the issues are appearing in order of Ld. DRP regarding TP Report mentions TNMM

AJAY KUMAR GUPTA,PANIPAT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, appeal of the assessee is allowed

ITA 3448/DEL/2025[2018-19]Status: DisposedITAT Delhi11 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2018-19]

Section 1Section 144BSection 147Section 250Section 263Section 69C

69C are not applicable on the facts of the case. 4. That the Ld. PCIT grossly erred in law & on the facts & circumstances of the case in passing the impugned order on the basis of incorrect reasons. 5. That the Ld. PCIT grossly erred in law & on the facts & circumstances of the case in passing the impugned order merely

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),HARYANA vs. ITO,WARD 14 (3) , NEW DELHI

In the result, the appeal filed by the assessee being ITA

ITA 2060/DEL/2022[2017-18]Status: DisposedITAT Delhi21 Mar 2025AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

Transfer Pricing ('TP') documentation, modifying the same with his own analysis and in doing so: 7.1. erred in not appreciating that none of the conditions set out in section 92C(3) of the Act are satisfied in the present case. 7.2. contravened section 92C of the Act read with Rule IOB(2) of the Rules, by rejecting/ excluding the comparable

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),GURGAON vs. ITO,WARD-14(3), NEW DELHI

In the result, the appeal filed by the assessee being ITA

ITA 2061/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Mar 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri S.K. Jhadav, CIT DR
Section 144Section 37Section 92CSection 92C(3)Section 92D

Transfer Pricing ('TP') documentation, modifying the same with his own analysis and in doing so: 7.1. erred in not appreciating that none of the conditions set out in section 92C(3) of the Act are satisfied in the present case. 7.2. contravened section 92C of the Act read with Rule IOB(2) of the Rules, by rejecting/ excluding the comparable

BHARTIYA INTERNATIONAL LTD,NEW DELHI vs. DCIT,CIRCLE-4(2), NEW DELHI

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

ITA 2109/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jan 2024AY 2017-18

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri Amit Goel, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 156

transferred in overseas jurisdiction. We thus find force in the plea of the assessee that in the instant case where the overseas agents I.T.A. No.2109/Del/2022 11 were paid commission for securing order etc., and such services were utilised for the purpose of making or earning income from a source outside India, the assessee is under no obligation to apply with

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 798/DEL/2017[2010-11]Status: DisposedITAT Delhi30 Nov 2023AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 795/DEL/2017[2007-08]Status: DisposedITAT Delhi30 Nov 2023AY 2007-08

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 794/DEL/2017[2006-07]Status: DisposedITAT Delhi30 Nov 2023AY 2006-07

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 797/DEL/2017[2009-10]Status: DisposedITAT Delhi30 Nov 2023AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 799/DEL/2017[2011-12]Status: DisposedITAT Delhi30 Nov 2023AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

ITA 796/DEL/2017[2008-09]Status: DisposedITAT Delhi30 Nov 2023AY 2008-09

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

Section 132(1)Section 133ASection 147

transfer of land transaction and addition added interest too. 3. Such expenditure which is impugned addition has never been recorded. 4. The Assessing Officer has given the finding that assessee has incurred liability of interest expenditure proceeded to invoke Section 69C to make addition. 5. Ld. CIT(A) has erred in confirming the entire addition for NH-8 deal

DEFSYS SOLUTIONS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-15, NEW DELHI

In the result the appeal of the assessee in ITA No

ITA 758/DEL/2023[2019-20]Status: DisposedITAT Delhi28 Mar 2024AY 2019-20

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 115BSection 139(1)Section 144CSection 153ASection 156Section 270ASection 271ASection 274Section 36(1)(va)Section 37(1)

69C read with section 115BBE of the Act. 4.1 That the Ld. AO has erred in not considering the documentary evidences, in the form of confirmation and cheque, submitted by the assessee and merely rejected them without pointing out any defect in the same. 4.2 That the Ld. AO has erred in making addition on the basis of presumption

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

ITA 4067/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

69C r.w.s. 115BBE of the Act. 14. Ld. AR further submits that in first appeal, before Ld. CIT(A), it was claimed by the assessee that since reassessment proceedings under challenged were initiated u/s 148 on the basis of the documents/evidences found during the course of search carried out in its own case on 28.07.2021 and further on 04.01.2022 therefore

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

ITA 4115/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

69C r.w.s. 115BBE of the Act. 14. Ld. AR further submits that in first appeal, before Ld. CIT(A), it was claimed by the assessee that since reassessment proceedings under challenged were initiated u/s 148 on the basis of the documents/evidences found during the course of search carried out in its own case on 28.07.2021 and further on 04.01.2022 therefore

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

transfer the assets or documents, which he believes belongs to the assessee, to the assessing officer having jurisdiction over that assessee. The assessing officer of the assessee on receipt of such asset or document seized would have jurisdiction to commence proceedings under Section 153C of the Act. The assessing officer has, thereafter, to apply his mind as to whether