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37 results for “transfer pricing”+ Survey u/s 133Aclear

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Key Topics

Section 10(38)40Section 8035Addition to Income34Section 143(3)29Survey u/s 133A28Section 133A25Section 14720Section 69B16Disallowance16Section 12A

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

ACIT (CENTRAL UJJAIN, UJJAIN vs. M/S ARIHANT FUTURE AND COMMODITIES LTD, INDORE

Showing 1–20 of 37 · Page 1 of 2

14
Section 6811
Long Term Capital Gains8
ITA 734/IND/2019[2016-17]Status: DisposedITAT Indore31 Mar 2022AY 2016-17

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

survey u/s 133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s

THE ACIT ,CENTRAL-UJJAIN, INDORE vs. M/S ARIHANT CAPITALS MARKETS LTD , INDORE

ITA 11/IND/2021[2014-15]Status: DisposedITAT Indore21 Mar 2022AY 2014-15

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

survey u/s 133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s

THE ACIT, CENTRAL - UJJAIN, INDORE vs. M/S ARIHANT FUTURE & COMMADITIES LTD , INDORE

ITA 10/IND/2021[2014-15]Status: DisposedITAT Indore21 Mar 2022AY 2014-15

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

survey u/s 133A was carried out on 29.12.2015 which continued till 02.01.2016. Regular assessment u/s 143(3) was made by Deputy Commissioner of Income Tax (Central – 1), Indore on 16.12.2016 wherein the returned income was accepted. Later on the case was reopened u/s 148 vide notice dated 10.12.2018 and the reassessment proceedings were completed by passing the order u/s

VIJAY RADHESHYAM NYATI HUF,DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 704/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

survey u/s 133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

SMT. MAMTA NYATI DHAMNOD DISTT. DHAR,DHAMNOD vs. ITO DHAR, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 488/IND/2019[2014-15]Status: DisposedITAT Indore25 May 2021AY 2014-15

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

survey u/s 133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

SMT VIJAYA NYATI, DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 703/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

survey u/s 133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

MANISH KUMAR RADHESHYAM NYATI ,DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 705/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

survey u/s 133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

KUMARI AYUSHI NYATI,INDORE vs. ITO-5(5), INDORE

In the result appeals of the assessee(s) namely Kumari

ITA 203/IND/2019[2014-15]Status: DisposedITAT Indore25 May 2021AY 2014-15

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

survey u/s 133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

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)

u/s. 133A was conducted on 18.12.2014 i.e. is the same date on which similar survey operation was conducted by the Investigation Wing Ahmadabad. The Ld. CIT(A) has reproduced the relevant part of the said order of ITAT Calcutta Bench in para 4.2.4 of first appellate order (supra). From vigilant reading of order of ITAT Calcutta Bench in the case

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)

u/s. 133A was conducted on 18.12.2014 i.e. is the same date on which similar survey operation was conducted by the Investigation Wing Ahmadabad. The Ld. CIT(A) has reproduced the relevant part of the said order of ITAT Calcutta Bench in para 4.2.4 of first appellate order (supra). From vigilant reading of order of ITAT Calcutta Bench in the case

M/S SUPREMO INDIA LTD ,INDORE vs. THE AIT CENTRAL 3, INDORE

In the result, appeal of assessee is allowed

ITA 29/IND/2023[2019-20]Status: DisposedITAT Indore07 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Supremo India Pvt. Ltd. Acit Central-3 400/2, Halka Patwari No.52 Indore Vs. Badiakeema Dudhiya, B.O. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcs 9822 C Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 07.06.2023

Section 115BSection 131(1)Section 133ASection 69ASection 69B

u/s 133A during the course of survey and the surrender letter dated 21.10.2016 submitted by the assessee at the time of survey and these documents are very much part of the records which is available at the time of assessment as well as at the time of examination by the ld PCIT. In the statement Page 19 of 29 Supremo

M/S. BHOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 490/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 411/IND/2013[2006-07]Status: DisposedITAT Indore31 Jan 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 412/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE LTD., DEWAS

In the result ground No.3& 4 are dismissed

ITA 634/IND/2014[2010-11]Status: DisposedITAT Indore31 Jan 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

THE DCIT, 1(1), UJJAIN vs. M/S BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 137/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

M/S BHOOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 142/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

M/S BHOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ACIT 1(1), UJJAIN

In the result ground No.3& 4 are dismissed

ITA 263/IND/2013[2006-07]Status: DisposedITAT Indore31 Jan 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

u/s 133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case

DECENT INDUSTRIES P. LTD.,BHOPAL vs. ITO-1(2), BHOPAL

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

survey action u/s 133A carried out in the case of one ‘Shri Anand Sharma, Kolkata’ (entry operator) on 02.07.2013 pursuant to which the statements of Shri Anand Sharma were recorded on 02.07.2013/06.02.2014. The AO observed that Shri Anand Page 2 of 44 M/s Decent Industries Pvt. Ltd ITA No. 356/Ind/2023 – AY 2012-13 Sharma was engaged in providing accommodation