BharatTax.net
SearchITATHigh CourtsSupreme CourtAI 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.

29 results for “transfer pricing”+ Section 148(2)clear

Sorted by relevance

Mumbai603Delhi426Hyderabad159Jaipur145Chennai133Bangalore125Kolkata72Chandigarh69Cochin69Ahmedabad67Rajkot58Pune40Raipur32Indore29Nagpur26Surat23Lucknow22Guwahati19Visakhapatnam17Cuttack12Agra10Jodhpur8Amritsar8Patna5Dehradun3Allahabad3Varanasi2Jabalpur2

Key Topics

Section 14749Section 143(3)45Section 8042Section 14830Addition to Income25Section 143(2)15Section 12A14Section 153A12Disallowance12

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

2 Smt. Nilima Kothari was resumed in 2016. There being no other documents or evidence to reveal that the income chargeable to tax had escaped assessment, proceedings initiated under section 147 of the Act on the ground that appellant was indulged in manipulating the share price without any corroborative evidences against her is wholly unjustified, improper

Showing 1–20 of 29 · Page 1 of 2

Section 689
Deduction8
Survey u/s 133A6

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

ITA 486/IND/2024[2012-13 ]Status: DisposedITAT Indore10 Sept 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 508/IND/2024[2012-13]Status: DisposedITAT Indore10 Sept 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 489/IND/2024[2017-18]Status: DisposedITAT Indore10 Sept 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

ITA 444/IND/2024[2016-17]Status: DisposedITAT Indore10 Sept 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 510/IND/2024[2017-18]Status: DisposedITAT Indore10 Sept 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 509/IND/2024[2016-17]Status: DisposedITAT Indore10 Sept 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 147Section 148Section 80

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

In the result, appeal of the assessee in ITANo

ITA 548/IND/2019[2010-11]Status: DisposedITAT Indore13 Oct 2021AY 2010-11

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

148 dated 28.03.2017 are unlawful, bad in law and without jurisdiction hence the assessment made be kindly cancelled. 2. That on the facts & in the circumstances of the case and in law, the learned lower authorities erred and in not justified in assessing the income of the assessee as the income from business and profession

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

ITA 90/IND/2019[-]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

148 dated 28.03.2017 are unlawful, bad in law and without jurisdiction hence the assessment made be kindly cancelled. 2. That on the facts & in the circumstances of the case and in law, the learned lower authorities erred and in not justified in assessing the income of the assessee as the income from business and profession

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

ITA 38/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18
Section 131Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 69C

Price Waterhouse & Co Vs. Deputy Commissioner of Income\nTax, Circle-22, ITA No. 1985/Kol2018 Order dated 5/2/2020, it\nwas observed:-\n“11. Therefore, in the light of the aforesaid judicial precedents and other case\nlaws, we note that to initiate reopening of the assessment, the Ld. AO must\nhave 'reason to believe that income chargeable to tax has escaped assessment

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 235/IND/2021[2011-12]Status: DisposedITAT Indore30 Jan 2023AY 2011-12

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 226/IND/2021[2012-2013]Status: DisposedITAT Indore30 Jan 2023AY 2012-2013

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 227/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

2 8 Data analysis of the transactions undertaken by the appellant. 3 8.1 Details analysis of the trades found as a result of search and survey operations. 4 8.1 NMCE data and PAN field segregation. 5 8.4 Penalties levied by NMCE on the brokers. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 6 8.5 Enquires conducted with regard

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

2 8 Data analysis of the transactions undertaken by the appellant. 3 8.1 Details analysis of the trades found as a result of search and survey operations. 4 8.1 NMCE data and PAN field segregation. 5 8.4 Penalties levied by NMCE on the brokers. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 6 8.5 Enquires conducted with regard

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNE vs. THE ACIT NFAC, DELHI

In the result, appeal of assessee is partly allowed

ITA 84/IND/2022[2017-18/]Status: DisposedITAT Indore17 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 43(1)

transfer pricing documentation and economic analysis has passed an order dated 30.10.2018 under Section 92CA(3) of the Act determining the "Arm's Length Price" difference of Rs. 41,57,14,9471- in respect of royalty payment of its AE and Rs. 39,63,921/- in respect of international transactions relating to trading activities of the assessee. Thus, total upward

BIHARILAL,HOSHANGABAD vs. COMISSIONER OF INCOME TAX (APPEALS), NFAC-DELHI

Appeal is allowed for statistical purpose

ITA 278/IND/2025[2018-19]Status: DisposedITAT Indore19 Feb 2026AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2018-19 Assessment Unit Of Income- Biharilal, Tax Department S/O Gaurishankar, 508, Ward No. 15, बनाम/ Shobhapur, Vs. Hoshangabad (Assessee/Appellant) (Revenue/Respondent) Pan: Eonpb2765E Assessee By Ms. Saniya Farhaz Memon, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 19.02.2026

Section 142(1)Section 144Section 147Section 148Section 148ASection 50C(2)

transfer of land and in the ITR filed by the appellant in response to notice issued u/s 148. Ground5. The Learned Assessing Officer has erred in passing the assessment order without applying the provisions of Section 50C(2) of the Income Tax Act, 1961, regarding the valuation of the property. The Ld. AO has failed to consider the provisions allowing

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

ITA 244/IND/2017[2012-13]Status: DisposedITAT Indore25 Jan 2023AY 2012-13

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver

JCIT(OSD),-2(1),INDORE, INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

ITA 441/IND/2018[2014-15]Status: DisposedITAT Indore25 Jan 2023AY 2014-15

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

ITA 309/IND/2017[2013-14]Status: DisposedITAT Indore25 Jan 2023AY 2013-14

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver