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21 results for “transfer pricing”+ Section 260Aclear

Sorted by relevance

Delhi229Mumbai73Chennai24Jaipur21Kolkata11Dehradun10Nagpur6Surat4Amritsar4Hyderabad4Pune4Ahmedabad4Bangalore3Chandigarh3Lucknow3Allahabad3Indore3Jodhpur1Cochin1

Key Topics

Section 143(3)16Section 14715Section 14815Addition to Income14Section 80G9Section 688Disallowance7TDS7Deduction6Section 153A

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

transfer pricing adjustment has been made in pursuance of provisions of clause (i) of sec. 92BA of the Act, which is in relation to expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of sub- section (2) of section 40A. We submit that the provision of Section

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

Showing 1–20 of 21 · Page 1 of 2

5
Section 405
Section 804
ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

transfer pricing adjustment has been made in pursuance of provisions of clause (i) of sec. 92BA of the Act, which is in relation to expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of sub- section (2) of section 40A. We submit that the provision of Section

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

section 139(1). In this case, assessee has not filed a revised to claim reliability charges of Rs. 1.50 per unit in computing Transfer Price of Power for the purpose of deduction u/s 80-1A of the Act and therefore, same was rightly rejected by the Ld. CIT(A). However, Hon'ble ITAT has allowed the same without giving

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMSSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

price. A loss is obviously created. Illustration X wants a manufactured loss of Rs 100 to reduce taxable income. While Y wants to launder Rs 100 untaxed money. A broker puts X and Y on the opposite SIDE of a series of trades in some options contracts that is in effect substance less. The trades will be matched such that

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 531/JPR/2025[2011-12]Status: DisposedITAT Jaipur10 Oct 2025AY 2011-12
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 147Section 148Section 68

transfer from\nother party and subsequently, sold same in stock exchange - However, there were no\ndiscrepancies in documents filed by assessee claiming deductions under section\n10(38) - Further, even though all characteristics of penny stock existed in present\ncase, still revenue had not brought on record any materials linking assessee in any of\ndubious transactions relating to entry, price rigging

INCOME TAX OFFICER, WARD-6(2), JAIPUR, NCR BUILDING, STATUE CIRCLE JAIPUR vs. VASUDEV HEMRAJANI, ARJUN NAGAR, JAIPUR

The appeal of the revenue stands dismissed

ITA 634/JPR/2024[2020-2021]Status: DisposedITAT Jaipur05 Sept 2024AY 2020-2021

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anil Dhaka, CIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250Section 68

260A of the Income Tax Act, 1961 (hereinafter referred to as, the Act) to challenge order dated 28.4.1999 passed by the Income Tax Appellate Tribunal (for short, the Tribunal), Amritsar Bench, Amritsar, whereby order dated 14.3.1990 passed by the Commissioner of Income Tax (Appeals), Bhatinda setting aside the assessment order, has been affirmed. The revenue has framed the following questions

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 695/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Sept 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 694/JPR/2025[2015-16]Status: DisposedITAT Jaipur10 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

AGRASEN PRIMSES PRIVATE LIMITED,JAIPUR vs. ITO WARD 5(1), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 125/JPR/2023[2014-15]Status: DisposedITAT Jaipur30 May 2024AY 2014-15
For Appellant: Ms. Parba Rana (Adv.)&For Respondent: Shri A.S. Nehra (CIT)
Section 133ASection 142(1)Section 143(2)Section 143(3)

transferred the\nmoney from the normal banking channel. The report of the investigation wing\nrelied and reproduced some of the content of its is in relation to the claim of the\nunaccounted income into the claim of exempt income without payment of tax,\nwhereas the fact in this case the assessee has invested the money out of the\ndisclosed source

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 132(4)Section 153ASection 68

260A of the Act. The\nappeal had been admitted on two substantial questions relating to whether an\naddition of undisclosed income may be made on the basis of loose sheets found\nin the search, particularly when the assessee therein had accepted, in his sworn\nstatement, that the information contained in the sheets reflected his undisclosed\nincome. In that case

DINESH HALDIA,JAIPUR vs. DCIT CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal of the assessee is partly allowed

ITA 384/JPR/2024[2007-08]Status: DisposedITAT Jaipur30 Jul 2024AY 2007-08

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Dheeraj Borad, CAFor Respondent: Sh. Arvind Kumar, CIT
Section 132(1)Section 133ASection 139(1)Section 153ASection 260ASection 69C

260A (Set-Aside) r.w.s. 153A of the Act on17.10.2018. I 6 Dinesh Haldia vs. DCIT have found that the AO passed order in light of Judgment pronounced by the Hon'ble High Court. The Ld. A.O. in para 11 of the assessment order has held the purchases of Rs. 13,00,000/- to be bogus and further that there

NASH FASHION (INDIA) LIMITED,JAIPUR vs. DCIT CIRCLE -2, JAIPUR

In the result, the appeal of the assessee is allowed in ITA no

ITA 159/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT a
Section 1Section 143(3)Section 40Section 80G

price of the equipments purchased directly by the done insitution. The first scenario will not qualify for deduction as what has been donated is property in kind, however the second scenario will qualify for deduction as what has been spent and transferred is sum of money and not property in kind. In our view, the facts of the present scenario

ASSISTANT COMMISSIONER OF INCOME-TAX, JAIPUR vs. NASH FASHION(INDIA) LIMITED, JAIPUR

In the result, the appeal of the assessee is allowed in ITA no

ITA 89/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT a
Section 1Section 143(3)Section 40Section 80G

price of the equipments purchased directly by the done insitution. The first scenario will not qualify for deduction as what has been donated is property in kind, however the second scenario will qualify for deduction as what has been spent and transferred is sum of money and not property in kind. In our view, the facts of the present scenario

NASH FASHION (INDIA) LIMITED,JAIPUR vs. DCIT CIRCLE 1, JAIPUR

In the result, the appeal of the assessee is allowed in ITA no

ITA 160/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14
For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT
Section 40Section 80G

price of the equipments purchased directly\nby the done insitution. The first scenario will not qualify for deduction as what\nhas been donated is property in kind, however the second scenario will qualify\nfor deduction as what has been spent and transferred is sum of money and not\nproperty in kind. In our view, the facts of the present scenario

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016
For Respondent: \nMrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

price) from the concerning person of all the 22 plots has not been taken in\nbooks.\n\n4. The trust property is used Personal benefit of the president\nShri Tejndra Pal Singh has taken loan & advances of Rs.31,50,000/- from the\ntrust and violated the provisions of section 13(2) of the Act. Further no proper\nbooks of accounts