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36 results for “transfer pricing”+ Section 11(4)clear

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Key Topics

Section 92B34Section 143(3)22Addition to Income14Section 6813Section 143(2)11Section 26310Section 43B8Section 92C7Transfer Pricing

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 53/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

4. On the other hand, the ld. Sr.DR heavily relied on the orders of the lower authorities by submitting that any subsequent omission of any provision of the Act would not operate retrospectively unless it specifically provided in the Act. The ld. Sr.DR while referring to the provisions of the Act submitted that there is no specific mention of fact

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 54/GTY/2025[2016-17]Status: DisposedITAT Guwahati

Showing 1–20 of 36 · Page 1 of 2

7
Section 2506
Disallowance5
Exemption4
13 Mar 2026
AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

4. On the other hand, the ld. Sr.DR heavily relied on the orders of the lower authorities by submitting that any subsequent omission of any provision of the Act would not operate retrospectively unless it specifically provided in the Act. The ld. Sr.DR while referring to the provisions of the Act submitted that there is no specific mention of fact

ACIT, CIRCLE - TINSUKIA , TINSUKIA vs. M/S. GREENPLY INDUSTRIES LTD., TINSUKIA

In the result, the appeal of the assessee for A

ITA 359/GTY/2019[2014-15]Status: DisposedITAT Guwahati21 Jun 2022AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

Transfer Pricing Officer (in short ‘TPO’) within the meaning of section 92CA of the Income Tax Act after necessary approval. Subsequently ld. TPO passed the order under section 92CA of the Act on 27.10.2017 suggesting the upward adjustment of Rs.43,67,295/- for Corporate Guarantee given by the assessee to its Associated Enterprises (AE) and downward adjustment in respect

GREENPLY INDUSTRIES LIMITED,TINSUKIA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA

In the result, the appeal of the assessee for A

ITA 232/GTY/2019[2014-15]Status: DisposedITAT Guwahati21 Jun 2022AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

Transfer Pricing Officer (in short ‘TPO’) within the meaning of section 92CA of the Income Tax Act after necessary approval. Subsequently ld. TPO passed the order under section 92CA of the Act on 27.10.2017 suggesting the upward adjustment of Rs.43,67,295/- for Corporate Guarantee given by the assessee to its Associated Enterprises (AE) and downward adjustment in respect

M/S. BHARTIA-SMSIL(JV),GUWAHATI vs. INCOME TAX OFFICER, WARD-3(1), GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 117/GTY/2019[2014-15]Status: DisposedITAT Guwahati17 Jun 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.117/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Sanjay Modi, FCAFor Respondent: Shri M.K. Dal, Addl. CIT, Sr. Dr
Section 143(3)Section 263Section 3Section 92BSection 92C

Transfer Pricing Officer(TPO) under section 92CA related party transactions amounting to Rs.51,08,99,031/- which is falling within the meaning of'specified domestic transactions' under section 92BA(i) of the Income Tax Act, 1961 to arrive at the Arm's Length Price (ALP) u/s 92C of the Act as required in terms of CBDT InstructionNo. 3/2016 dated

SHREE SAI SMELTERS (I) LIMITED,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 228/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.228/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shree Shai Smelters (I) Ltd. Vs. Acit, Circle-Shillong

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

section 92BA w.e.f 01.04.2017 had the effect of it being omitted from its inception hence, reference 2 Shree Shai Smelters (I) Ltd. Assessment Year:2014-15 to Transfer Pricing Officer (TPO) is bad in law.The ld. Counsel for the assessee submitted that the present issue is squarely covered by the above said order of the Tribunal, a copy of which

SHIVANI ISPAT AND ROLLING MILL (P) LTD.,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 227/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.227/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shivani Ispatand Rolling Mill Vs. Acit, Circle-Shillong (P) Ltd. 13Th Mile, Tamulkuchi, Byrnihat, G.S. Road, Ri-Bhoi, Meghalaya "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aafcs 3465 B (Appellant) .. (Respondent) Appellant By :Shri J.P. Gupta, Fca Respondent By :Shri T. Hunar, Jcit, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 15/06/2020 घोषणाक"तार"ख/Date Of Pronouncement : 31/07/2020 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15, Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeal)- Shillong, In Appeal No. Cit(A)/Shg/10083/2018-19 Dated 17.04.2019, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) / 92C(4) / 263 Of The Income Tax Act, 1961 (In Short The ‘Act’) Dated 30/11/2018. 2.When This Appeal Was Called Out For Hearing, The Ld. Counsel For The Assessee Invited Our Attention To The Order Dated 10.06.2020, Passed By The Tribunal In The Case Of M/S Raipur Steel Casting India (P) Ltd. & Srinath Ji Furnishing Pvt. Ltd. In I.T.A. No. 895& 1035/Kol/2019, For Assessment Year 2014-15.Wherein Thetribunal Held That Effect Of Omission Of Clause (I) Of Section 92Ba W.E.F 01.04.2017 Had The Effect Of It Being Omitted From Its Inception Hence, Reference

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

section 92BA w.e.f 01.04.2017 had the effect of it being omitted from its inception hence, reference 2 Shivani Ispat and Rolling Mill (P) Ltd. Assessment Year:2014-15 to Transfer Pricing Officer (TPO) is bad in law. The ld. Counsel for the assessee submitted that the present issue is squarely covered by the above said order of the Tribunal

ASSAM BIO ETHANOL PRIVATE LIMITED,GUWAHATI vs. ITO W-1(1), GUWAHATI, GUWAHATI

Appeal is partly allowed

ITA 288/GTY/2024[2021-22]Status: DisposedITAT Guwahati16 Oct 2025AY 2021-22

Bench: The Drp Was That The

Section 143(3)Section 144Section 144C(3)

section 1448 of the Act, pursuant to the directions of the Hon'ble DRP in assessing the income of the Appellant as INR 36,32,060/- for Assessment Year (AV) 2021-22 as against the returned loss of INR 11,078,992 declared by the Appellant. Ground 2: The Ld. AO/ Learned Assistant Commissioner of Income Tax, Transfer Pricing

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 8/GTY/2016[2011-12]Status: DisposedITAT Guwahati06 Oct 2023AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

Pricing Officer during the course of assessment/reassessment proceedings. These time limits are either from the end of the financial year in which the notice for initiation of the proceedings was served or from the end of the assessment year to which the proceedings relate. It is proposed to amend the aforesaid sections, i.e., 153 and 153B so as to provide

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 211/GTY/2014[2010-11]Status: DisposedITAT Guwahati06 Oct 2023AY 2010-11

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

Pricing Officer during the course of assessment/reassessment proceedings. These time limits are either from the end of the financial year in which the notice for initiation of the proceedings was served or from the end of the assessment year to which the proceedings relate. It is proposed to amend the aforesaid sections, i.e., 153 and 153B so as to provide

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share

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

section 10(38) of the Income Tax Act. In the meantime, the operators regulate the price of the stock and gradually rise its price many times than its actual price. Often it rigged to as many as 500 to 1000 times of the purchase price. Thereafter ld. Assessing Officer has observed that how DIT Investigation was required to share