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19 results for “transfer pricing”+ Section 10(38)clear

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Key Topics

Section 683Addition to Income3Section 143(3)2Section 143(2)2Exemption2

D.C.I.T., CIRCLE-1, DIBRUGARH vs. SHEETAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 64/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 51/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 52/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 53/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 54/GTY/2023[2015-16]Status: DisposedITAT Guwahati01 Sept 2023AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 55/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ BAMALWA (HUF), DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 56/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. USHA BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 57/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. MEENAKSHI BAMALWA SONI, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 58/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. VINOD BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 66/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. BHAGWATI DEVII BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 59/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. VISHAL BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 60/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. PRAMOD KUMAR BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 65/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. VINAY BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 61/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. RAVI BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 62/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

D.C.I.T., CIRCLE-1, DIBRUGARH vs. MADAN LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 63/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transferred to the beneficiary at a very marginal price mostly online by way of preferential allotment or off-line sales. The beneficiaries hold the shares for one year or more, the statutory period for claiming long-term capital gain, which is exempt under section 10(38

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, DIBRUGARH vs. GREENPLY INDUSTRIES LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 140/GTY/2024[2013-14]Status: DisposedITAT Guwahati15 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

For Appellant: Shri Ashok Tulsyan, ARFor Respondent: Shri Sanjay Jha, DR
Section 115J

38. Inter-corporate guarantees are a common business practice. Within an affiliated corporate group, some entities represent higher credit risks than others. The weaker entities may either be unable to obtain financing or may be able to obtain credit facilities only upon unfavourable terms. When a corporate borrowing group includes multiple businesses, it is common for lenders to look

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. SHRI PANNALAL BHANSALI, GUWAHATI

In the result, appeal of the revenue as well as the Cross

ITA 428/GTY/2019[2016-17]Status: DisposedITAT Guwahati31 Aug 2023AY 2016-17

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2016-17

For Respondent: Shri P. S. Thuingaleng, ACIT
Section 10(38)Section 143(2)Section 143(3)Section 68

38) of the Act towards LTCG. To examine the genuineness of claim of LTCG, Ld. AO called for details of shares of RSWM Ltd. on which this LTCG was claimed as exempt. From the DMAT account furnished by the assessee, Ld. AO noted certain discrepancies in respect of the opening balance of shareholding and thus concluded that the claim

ACCRECENT WAY MARKETING (P) LTD.,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

ITA 358/GTY/2018[2010-11]Status: DisposedITAT Guwahati09 Jun 2025AY 2010-11

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 251Section 68

prices of the scripts of very little known companies. 25. While on this issue it would be beneficial to take note of the decision in Yadu Hari Dalmia v. Commissioner of Income Tax, Delhi (Central) (1980) 126 ITR 48 wherein it was held that the whole catena of sections starting from Section 68 have been introduced in the taxing enactment