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46 results for “transfer pricing”+ Section 152clear

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Key Topics

Section 143(3)55Section 8035Addition to Income35Section 26321Section 194H20Section 12A18Section 201(1)14Section 194J14Section 153A12

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

transferring PAN of the assesse society from DCIT(E), Bhopal to ACIT(central) -2 Bhopal. Once the PAN is migrated then CIT(E) seize to have any jurisdiction over the assessee with regard to any of proceedings under the Act. We accordingly dismiss the additional grounds raised by the assessee. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 15. Apropos

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

In the result, appeal of the assessee in ITANo

Showing 1–20 of 46 · Page 1 of 3

Disallowance11
Deduction10
Revision u/s 2637
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

transferring PAN of the assesse society from DCIT(E), Bhopal to ACIT(central) -2 Bhopal. Once the PAN is migrated then CIT(E) seize to have any jurisdiction over the assessee with regard to any of proceedings under the Act. We accordingly dismiss the additional grounds raised by the assessee. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 15. Apropos

M/S RUCHI J OIL PVT LTD ,MUMBAI vs. PCIT(A)UJJAIN, UJJAIN

In the result appeal of the assessee is allowed

ITA 176/IND/2020[2014-15]Status: DisposedITAT Indore25 Mar 2021AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15

Section 143(2)Section 143(3)Section 263Section 56(2)(viib)Section 92C

Transfer Pricing Officer (In short ‘ Ld.TPO”) u/s 92CA(1) of the Act for the computation of arms length price. Ld. TPO called for the necessary information after issuing notice u/s 92CA(2) of the Act and was of the view that no adjustment is required to be made to the arms length price of the transaction. After receiving the order

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 109/IND/2015[2012-13]Status: DisposedITAT Indore01 Aug 2024AY 2012-13

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

Section 194Section 194HSection 194JSection 201(1)

152. 3.7 The Ld.AR further submitted that, the issue of taxability of interconnectivity charges as FTS has been decided by Hon’ble Karnataka High Court in case of Vodafone South Ltd. reported in (2016) 72 taxmann.com 347 and that the revenue has accepted the said decision by Hon’ble Karnataka High Court which has been categorically noted

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 111/IND/2015[2013-14 (Quarter 4)]Status: DisposedITAT Indore01 Aug 2024

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

Section 194Section 194HSection 194JSection 201(1)

152. 3.7 The Ld.AR further submitted that, the issue of taxability of interconnectivity charges as FTS has been decided by Hon’ble Karnataka High Court in case of Vodafone South Ltd. reported in (2016) 72 taxmann.com 347 and that the revenue has accepted the said decision by Hon’ble Karnataka High Court which has been categorically noted

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 110/IND/2015[2013-14 (for first three quarter)]Status: DisposedITAT Indore01 Aug 2024

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

Section 194Section 194HSection 194JSection 201(1)

152. 3.7 The Ld.AR further submitted that, the issue of taxability of interconnectivity charges as FTS has been decided by Hon’ble Karnataka High Court in case of Vodafone South Ltd. reported in (2016) 72 taxmann.com 347 and that the revenue has accepted the said decision by Hon’ble Karnataka High Court which has been categorically noted

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

ITA 265/IND/2018[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

152. 3.7 The Ld.AR further submitted that, the issue of taxability of interconnectivity charges as FTS has been decided by Hon’ble Karnataka High Court in case of Vodafone South Ltd. reported in (2016) 72 taxmann.com 347 and that the revenue has accepted the said decision by Hon’ble Karnataka Page 19 of 65 ITA No. 415/Ind/2014 & 265/Ind/2018

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

ITA 415/IND/2014[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

152. 3.7 The Ld.AR further submitted that, the issue of taxability of interconnectivity charges as FTS has been decided by Hon’ble Karnataka High Court in case of Vodafone South Ltd. reported in (2016) 72 taxmann.com 347 and that the revenue has accepted the said decision by Hon’ble Karnataka Page 19 of 65 ITA No. 415/Ind/2014 & 265/Ind/2018

HASSANAND KHEMLANI,INDORE vs. THE PCIT-1 ,INDORE, INDORE

ITA 110/IND/2021[2016-17]Status: DisposedITAT Indore14 Mar 2023AY 2016-17

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: & Shri Santosh Deshmukh, A.RFor Respondent: Shri P. K. Mishra, CIT.D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 54Section 56(2)(vii)

152, Dravid Nagar, Indore, Indore Indore, Sudama Nagar S.O., Madhya Pradesh - 452001 PAN No. ACWPJ9728J & Hasanand Khemlani Pr.CIT-1 C/o Satnam S. Sheetal, 992- Indore Khatiwala Tank, Indore PAN No. AKTPK8941M (Appellant) .. (Respondent) Shri Satnam Singh Sheetal, A.R. Assessee by : & Shri Santosh Deshmukh, A.R. Revenue by : Shri P. K. Mishra, CIT.D.R. Date of Hearing 05.01.2023 Date of Pronouncement

KALPANA JAIN,INDORE vs. THE PR CIT-1, INDORE

ITA 138/IND/2021[2016-17]Status: DisposedITAT Indore14 Mar 2023AY 2016-17

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: & Shri Santosh Deshmukh, A.RFor Respondent: Shri P. K. Mishra, CIT.D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 54Section 56(2)(vii)

152, Dravid Nagar, Indore, Indore Indore, Sudama Nagar S.O., Madhya Pradesh - 452001 PAN No. ACWPJ9728J & Hasanand Khemlani Pr.CIT-1 C/o Satnam S. Sheetal, 992- Indore Khatiwala Tank, Indore PAN No. AKTPK8941M (Appellant) .. (Respondent) Shri Satnam Singh Sheetal, A.R. Assessee by : & Shri Santosh Deshmukh, A.R. Revenue by : Shri P. K. Mishra, CIT.D.R. Date of Hearing 05.01.2023 Date of Pronouncement

CHIRAYU CHARITABLE FOUNDATION,BHOPAL vs. PCIT (CENTRAL), BHOPAL

In the result appeal of the assessee stands allowed

ITA 179/IND/2019[-]Status: DisposedITAT Indore09 Feb 2021

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradchirayu Charitable Pcit (Central), Foundation,Bhopal Indore Bhopal Highway, Bhaisakhedi, Vs. Bhopal (Appellant) (Revenue ) Pan No.Aaaac3656P Revenue By Shri S.S. Mantri, Cit Appellant By S/Shri Sumit Nema, Sr. Advocate, Gagan Tiwari & Piyush Parashar, Advs Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R Per Manish Borad, Am.

Section 12ASection 132

transferred to the groups donation account through a journal entry passed on 29.8.2011. The assessment of the assessee was completed u/s 143(3) of the Act for Assessment Year 2011-12 on 18.3.2014 in normal course and during the course of proceedings confirmation of loan creditors were filed, copy of bank account of M/s Riviera Infoway Ltd along with

M/S. BIRLA CORPORATION LTD., UNIT SATNA CEMENT WORKS,SATNA vs. ITO (IT & TP), BHOPAL

In the result, Assessee’s appeals

ITA 34/IND/2020[2011-12]Status: DisposedITAT Indore28 Jan 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

152 Pubmatic India Pvt. Ltd. reported at ITR 100 (Mumbai ITAT) 10 Copy of Judgement of the Hon’ble Tribunal in the Case 153 to 172 of Mitsui & Co. Ltd. ITA No. 4377 (ITAT Delhi) 11 Copy of Judgement in the Case of Motorola Inc. (ITAT 173 to 289 Delhi) 8. Per contra Ld. DR vehemently argued supporting the order

M/S. BIRLA CORPORATION LTD., UNIT SATNA CEMENT WORKS,SATNA vs. ITO (IT & TP), BHOPAL

In the result, Assessee’s appeals

ITA 33/IND/2020[2010-11]Status: HeardITAT Indore28 Jan 2022AY 2010-11

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

152 Pubmatic India Pvt. Ltd. reported at ITR 100 (Mumbai ITAT) 10 Copy of Judgement of the Hon’ble Tribunal in the Case 153 to 172 of Mitsui & Co. Ltd. ITA No. 4377 (ITAT Delhi) 11 Copy of Judgement in the Case of Motorola Inc. (ITAT 173 to 289 Delhi) 8. Per contra Ld. DR vehemently argued supporting the order

THE ACIT (CENTRAL)-I, BHOPAL vs. M/S. D.K. CONSTRUCTION, BHOPAL

Appeal is allowed

ITA 36/IND/2022[2014-15]Status: DisposedITAT Indore31 Jan 2023AY 2014-15

Bench: Ms. Suchitra R. Kamble & Shri Bhagirath Mal Biyani

Section 143(3)Section 147Section 80

152, were released on 30.05.2012 / 26.02.2015. Ld. AR also carried us to subsequent Page No. 133 to 137 and demonstrated that ultimately the local-authority granted construction-permission over those 2 plots on 27.12.2012 / 14.09.2015 after release of mortgage. With these clinching evidences, the Ld. AR submitted that it is true that the layout plan was for 180 units

THE ACIT (CENTRAL)-I, BHOPAL vs. M/S. D.K. CONSTRUCTION, BHOPAL

Appeal is allowed

ITA 37/IND/2022[2017-18]Status: DisposedITAT Indore31 Jan 2023AY 2017-18

Bench: Ms. Suchitra R. Kamble & Shri Bhagirath Mal Biyani

Section 143(3)Section 147Section 80

152, were released on 30.05.2012 / 26.02.2015. Ld. AR also carried us to subsequent Page No. 133 to 137 and demonstrated that ultimately the local-authority granted construction-permission over those 2 plots on 27.12.2012 / 14.09.2015 after release of mortgage. With these clinching evidences, the Ld. AR submitted that it is true that the layout plan was for 180 units

M/S. D.K. CONSTRUCTION,BHOPAL vs. THE ACIT, 2(1), BHOPAL

Appeal is allowed

ITA 24/IND/2022[2017-18]Status: DisposedITAT Indore31 Jan 2023AY 2017-18

Bench: Ms. Suchitra R. Kamble & Shri Bhagirath Mal Biyani

Section 143(3)Section 147Section 80

152, were released on 30.05.2012 / 26.02.2015. Ld. AR also carried us to subsequent Page No. 133 to 137 and demonstrated that ultimately the local-authority granted construction-permission over those 2 plots on 27.12.2012 / 14.09.2015 after release of mortgage. With these clinching evidences, the Ld. AR submitted that it is true that the layout plan was for 180 units

THE ACIT (CENTRAL)-I, BHOPAL vs. M/S. D.K. CONSTRUCTION, BHOPAL

Appeal is allowed

ITA 35/IND/2022[2013-14]Status: DisposedITAT Indore31 Jan 2023AY 2013-14

Bench: Ms. Suchitra R. Kamble & Shri Bhagirath Mal Biyani

Section 143(3)Section 147Section 80

152, were released on 30.05.2012 / 26.02.2015. Ld. AR also carried us to subsequent Page No. 133 to 137 and demonstrated that ultimately the local-authority granted construction-permission over those 2 plots on 27.12.2012 / 14.09.2015 after release of mortgage. With these clinching evidences, the Ld. AR submitted that it is true that the layout plan was for 180 units

THE ACIT (CENTRAL)-I, BHOPAL vs. M/S. D.K. CONSTRUCTION, BHOPAL

Appeal is allowed

ITA 34/IND/2022[2012-13]Status: DisposedITAT Indore31 Jan 2023AY 2012-13

Bench: Ms. Suchitra R. Kamble & Shri Bhagirath Mal Biyani

Section 143(3)Section 147Section 80

152, were released on 30.05.2012 / 26.02.2015. Ld. AR also carried us to subsequent Page No. 133 to 137 and demonstrated that ultimately the local-authority granted construction-permission over those 2 plots on 27.12.2012 / 14.09.2015 after release of mortgage. With these clinching evidences, the Ld. AR submitted that it is true that the layout plan was for 180 units

ACIT CENTRAL-2 INDORE, INDORE vs. SHRI .GAURAV TEKRIWAL, INDORE

In the result, this appeal of Revenue is dismissed

ITA 62/IND/2021[2015-16]Status: DisposedITAT Indore21 Nov 2022AY 2015-16

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Acit, Central -2 Shri Gaurav Tekriwal Indore बनाम/ 204, Princess Valley, South Tukoganj, Indore Vs. (Appellant / Revenue) (Respondent / Revenue) Pan: Acppt 1628 Q Assessee By Shri Anil Kamal Garg, Arpit Gaur, Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 21.09.2022 Date Of Pronouncement 21.11.2022

Section 143(2)Section 143(3)Section 2Section 54FSection 55(2)(a)Section 57

152 CTR (MP) 227 : (1997) 224 TTR 106 (MP). In the said judgment, it was averred that the assessee sold her property at Jabalpur and realized capital of Rs. 31,980 out of which she invested a sum of Rs. 71,256 and purchased a house at Delhi. The exemption was claimed from the charge of tax on capital gain

SEWA SAHKARI SAMMITTEE MARYADIT,BEED, MUNDI KHANDWA vs. PCIT-1, INDORE

In the result, appeal by the assesse is allowed

ITA 44/IND/2022[2016-17]Status: DisposedITAT Indore30 Oct 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisewa Sahkari Sammittee Pr. Cit-2 Maryadit Beed Indore Vs. Beed Mundi Khandwa (Appellant / Assessee) (Revenue) Pan: Aaufs0703N Assessee By Shri Gagan Tiwari, Ar Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 05.10.2023 Date Of Pronouncement 30.10.2023

Section 12ASection 138Section 143(3)Section 263

price (MSP Samarthan Mulya) & other source is sale of fertilizers to farmers. (2) Please furnish the copy of following documents/detail for the AY 2016-17 (i.e. FY 2015-16). • Income Tax Return Attached for your reference • Computation of Income Attached for your reference Audit report with all annexure Attached for your reference ⚫ Profit & Loss A/c (With Schedule) Attached for your