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107 results for “transfer pricing”+ Section 153Cclear

Sorted by relevance

Delhi232Mumbai143Hyderabad107Chennai71Jaipur64Cochin63Bangalore56Chandigarh33Ahmedabad27Indore25Guwahati18Nagpur17Rajkot14Lucknow6Pune4Jodhpur3Surat2Amritsar1Varanasi1Visakhapatnam1

Key Topics

Section 153C137Section 26375Section 13263Addition to Income63Search & Seizure49Section 6947Section 139(1)42Section 143(3)30Section 144C23

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1225/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69

Showing 1–20 of 107 · Page 1 of 6

Section 153D22
Transfer Pricing13
Unexplained Investment13
Section 69A

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1222/HYD/2025[2016-17]Status: DisposedITAT Hyderabad25 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

SAMIUDDIN ASLAM,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, all the 4 appeals filed by the assessee are allowed

ITA 1224/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1222 To 1225/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2016-17 To 2019-20) Shri Samiudedin Aslam Vs. Asstt. Commissioner Of Hyderabad Income Tax, Central Circle 2(4) Hyderabad Pan: Ckvpa7727F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 22/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate Assessment Orders Passed By The A. O Under Section 153C R.W.S. 144C(13) Of The Income Tax Act, 1961, All Dated 17/01/2025, For The Assessment. Years 2016-17 To 2019- 20 Respectively. The Assessee Has Raised Similar Grounds For All The Four Assessment Years. Therefore, For The Sake Of Convenience

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 115BSection 132Section 144C(5)Section 153CSection 69Section 69A

Price of the assessee, but said extended time limit of 12 months is not available to an eligible assessee, which is evident from wordings of section 153B and fourth proviso provided thereon. Therefore, in our considered view, the arguments of the ld. CIT-DR does not hold good and thus, the A.O ought to have completed the assessment within

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 300/HYD/2023[2017-18]Status: DisposedITAT Hyderabad25 Sept 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. T.H. Vijaya Lakshmi, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153CSection 69

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

RAMESH CHANDRA MAJITHIA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 302/HYD/2023[2017-18]Status: DisposedITAT Hyderabad25 Sept 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. T.H. Vijaya Lakshmi, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153CSection 69

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

SIVA PRASAD REDDY BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 301/HYD/2023[2018-19]Status: DisposedITAT Hyderabad25 Sept 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. T.H. Vijaya Lakshmi, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153CSection 69

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 323/HYD/2023[2018-19]Status: DisposedITAT Hyderabad25 Sept 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. T.H. Vijaya Lakshmi, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153CSection 69

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

NAGA LAKSHMI BUCHEPALLI,CHIMAKURTHY vs. ACIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 322/HYD/2023[2017-18]Status: DisposedITAT Hyderabad25 Sept 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Ms. T.H. Vijaya Lakshmi, CIT-DR
Section 132Section 139(1)Section 143(2)Section 153CSection 69

transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -8 (1), HYDERABAD

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

ITA 83/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

transfer pricing study report. 4. On the facts and circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP, have erred in conducting a fresh search and modifying filters for identifying comparable companies. 5. On the facts and circumstances of the case and in law, the learned

EPAM SYSTEMS INDIA PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

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

ITA 498/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

transfer pricing study report. 4. On the facts and circumstances of the case and in law, the learned TPO and the learned AO under the directions of the Hon'ble DRP, have erred in conducting a fresh search and modifying filters for identifying comparable companies. 5. On the facts and circumstances of the case and in law, the learned

PULLALAREVU ANUSHA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 25/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 44/HYD/2023[2016-17]Status: DisposedITAT Hyderabad28 Feb 2023AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 45/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

VAMSI KRISHNA REDDY GOTEKE,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 46/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

GAVIREDDYGARI HARIKISHORE REDDY,ANANTHAPUR vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 4/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

PULLALAREVU ANUSHA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 24/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

KANIPAKAM HARI PRASAD REDDY ,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 21/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

RAMA SUBBA REDDY KUDUMULA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 38/HYD/2023[2019-20]Status: DisposedITAT Hyderabad28 Feb 2023AY 2019-20

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

SARITHA AGARWAL,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 76/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot

RAMA SUBBA REDDY KUDUMULA,HYDERABAD vs. ACIT, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, the appeal of assessee in ITA

ITA 37/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2023AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarsl.No.

Section 132Section 139(1)Section 153CSection 69

Section 153C of the Act. The reasons recorded in the satisfaction note cannot be improved upon or supplemented or substituted subsequently by learned CIT(A) by making reference to the seized annexures and agreements which are not part of the satisfaction note. Hence the findings of the Learned CIT(A) are against law and facts. The proposition that addition cannot