BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

38 results for “transfer pricing”+ Section 4clear

Sorted by relevance

Delhi5,497Mumbai5,330Bangalore2,045Chennai1,141Kolkata970Ahmedabad834Karnataka803Hyderabad796Pune788Jaipur482Surat326Chandigarh320Indore287Cochin245Visakhapatnam143Rajkot140SC132Telangana110Lucknow92Nagpur89Cuttack88Calcutta75Raipur72Amritsar55Jodhpur38Agra38Guwahati38Dehradun37A.K. SIKRI ROHINTON FALI NARIMAN17Jabalpur16Ranchi15Rajasthan14Varanasi13Panaji13Kerala13Allahabad12Patna11Orissa9Punjab & Haryana4Andhra Pradesh2A.K. SIKRI N.V. RAMANA1D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1S.B. SINHA MARKANDEY KATJU1MADAN B. LOKUR S.A. BOBDE1DIPAK MISRA V. GOPALA GOWDA1

Key Topics

Section 92B34Section 143(3)22Section 6817Addition to Income16Section 143(2)11Section 26310Section 43B8Transfer Pricing8Section 92C

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 Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective effect. In other words clause (i) of Section 92BA of the Act has been omitted by the Finance Act, 2017 w.e.f. 01/04/2017 without any saving clause and therefore, operates retrospectively. The ld. A.R. submitted that the issue involved in the appeal

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 Guwahati

Showing 1–20 of 38 · Page 1 of 2

7
Section 2506
Exemption5
Disallowance5
13 Mar 2026
AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective effect. In other words clause (i) of Section 92BA of the Act has been omitted by the Finance Act, 2017 w.e.f. 01/04/2017 without any saving clause and therefore, operates retrospectively. The ld. A.R. submitted that the issue involved in the appeal

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

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

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

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

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)

Transfer 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

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)

Transfer 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

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

Transfer Pricing Guidelines 2010 supports this view in para 7.13 where it is explained that where higher credit rating of Associated Enterprise is due to a guarantee by another group member, such association positively enhances the profit making potential of that Associated Enterprise. We, therefore, find ourselves in agreement with the contention of the Id. D.R. that there

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

M/S. G.D. MARKETING PRIVATE LIMITED,GUWAHATI vs. INCOME TAX OFFICER, WARD-2(1), GUWAHATI`

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 425/GTY/2019[2015-16]Status: DisposedITAT Guwahati28 Apr 2021AY 2015-16

Bench: Shri Sanjay Garg

Section 2Section 2ASection 40ASection 40A(2)Section 40A(2)(b)Section 92B

4 of7 the case of CIT Vs. GE Thermometrics India Pvt. Ltd., in ITA No. 876/2008 in which while dealing the omission sub-section (9) of Section 1 OB the Hon'ble High Court has held that once the section is omitted from the statute book, the result is it had never been passed and be considered

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

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. 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

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. 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

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. 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

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. 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

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. 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. 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

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