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177 results for “transfer pricing”+ Section 36(1)(vii)clear

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Key Topics

Section 143(3)93Addition to Income69Section 153A52Section 6849Section 13233Section 133A26Search & Seizure26Section 80I25Section 8019

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

ITA 887/JPR/2019[2013-14]Status: DisposedITAT Jaipur20 Jan 2021AY 2013-14
For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a
Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

Showing 1–20 of 177 · Page 1 of 9

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Section 14818
Disallowance18
Survey u/s 133A12
ITA 886/JPR/2019[2012-13]Status: DisposedITAT Jaipur20 Jan 2021AY 2012-13
For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a
Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

ITA 888/JPR/2019[2014-15]Status: DisposedITAT Jaipur20 Jan 2021AY 2014-15
For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a
Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

ITA 187/JPR/2022[2017-18]Status: DisposedITAT Jaipur04 Oct 2022AY 2017-18
For Appellant: Sh. Prakul Khurana (Adv.) &For Respondent: Sh. Sanjay Dhariwal (CIT)
Section 143(1)Section 143(3)Section 14ASection 263Section 36(1)(va)

section 14A(1), deduction of that expenditure is not to be allowed which has been incurred by the assessee in relation to income which does not form part of the total income under this Act. Axiomatically, it is that expenditure alone which has been incurred in relation to the income which is includible in total income that

M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

ITA 744/JPR/2018[2014-15]Status: DisposedITAT Jaipur13 May 2022AY 2014-15
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

vii) Allowing rent of Rs. 7,13,862/- paid to a person specified u/s 40A(2)(b); viii) Holding that the donation of Rs. 76,15,213/- made by the assessee to DAV Trust was expenditure incurred wholly and exclusively for the purpose of business of the assessee; ix) Deleting the addition of Rs. 13,31,39,886/- made

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 201/JPR/2017[2012-13]Status: DisposedITAT Jaipur13 May 2022AY 2012-13
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

vii) Allowing rent of Rs. 7,13,862/- paid to a person specified u/s 40A(2)(b); viii) Holding that the donation of Rs. 76,15,213/- made by the assessee to DAV Trust was expenditure incurred wholly and exclusively for the purpose of business of the assessee; ix) Deleting the addition of Rs. 13,31,39,886/- made

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 291/JPR/2017[2013-14]Status: DisposedITAT Jaipur13 May 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

vii) Allowing rent of Rs. 7,13,862/- paid to a person specified u/s 40A(2)(b); viii) Holding that the donation of Rs. 76,15,213/- made by the assessee to DAV Trust was expenditure incurred wholly and exclusively for the purpose of business of the assessee; ix) Deleting the addition of Rs. 13,31,39,886/- made

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

DCIT, C-4, JAIPUR vs. M/S. JLC ELECTROMET PVT. LTD., JAIPUR

In the result, the appeal of the Department is dismissed

ITA 166/JPR/2020[2016-17]Status: DisposedITAT Jaipur12 Apr 2022AY 2016-17
For Appellant: Shri Mahendra GargieyaFor Respondent: Shri A.S. Nehra, Addl. CIT
Section 142(1)Section 143(2)Section 195Section 40Section 9(1)(vii)

section 40(a)(i) was warranted-Revenue's Appeal dismissed." 8.10 DCIT Vs. Avt Mccormick Ingredients Ltd. (2016) 137 DTR 0092(Chennai)(Trib) Business Expenditure-Interest, commission, brokerage etc. to a resident Disallowance Disallowance of Lab Analysis Fee-Non-deduction of TDS-Assessee company filed return of income with total income of Rs.12,91,49,070/- and case was selected

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

price paid for acquiring the rights of land and not the land itself and the ownership of the land vests with the lessor of the land. The lessee is liable to return the land to its original owner after the expiry of the lease and does not have ownership rights over the land. On such facts, courts have held that

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act\nin respect of the amounts said to have been invested in subsidiaries/group\ncompanies/associates\nand to remit the matter to Learned Assessing\nOfficer for decision afresh so as to record finding as to interest free funds\navailable with the assessee during the assessment years under\nconsideration, after verification of all relevant documents relied on behalf

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act\nin respect of the amounts said to have been invested in subsidiaries/group\ncompanies/associates\nand to remit the matter to Learned Assessing\nOfficer for decision afresh so as to record finding as to interest free funds\navailable with the assessee during the assessment years under\nconsideration, after verification of all relevant documents relied on behalf

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

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

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

36(1)(va) | | | Distributed income u/s 115Q (to be taxed @ | Rs. 71,99,99,211/- | | 20%) | | - 4. The assessee has filed objections to the draft assessment order in Form no. 35A on 25.10.2023 before the Dispute Resolution Panel [DRP]. The DRP vide order dated 30.06.2024 given the direction u/s 144C

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the Revenue in ITA No

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONEROF INCOME TAX, CIRCLE -2, AJMER, AJMER

In the result, the appeal of the Revenue in ITA No

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation