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152 results for “transfer pricing”+ Section 45(2)clear

Sorted by relevance

Mumbai1,118Delhi887Chennai241Hyderabad227Bangalore225Jaipur152Ahmedabad149Chandigarh122Kolkata96Cochin78Indore74Rajkot66Pune65Surat41Visakhapatnam40Raipur32Nagpur29Amritsar22Guwahati21Cuttack18Jodhpur17Lucknow15Varanasi6Jabalpur3Panaji2Agra1Dehradun1Ranchi1

Key Topics

Section 143(3)83Addition to Income72Section 6838Section 80I36Disallowance30Section 26321Section 14819Section 234A19Section 153A18

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

In the result of the appeal of the assessee is allowed

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

45,257 after TP adjustment Difference 3,18,71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance can be made

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

Showing 1–20 of 152 · Page 1 of 8

...
Section 14318
Deduction18
Business Income12
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

45,257 after TP adjustment Difference 3,18,71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance can be made

NARAIN LAL AGRAWAL,JAIPUR vs. DCIT CIRCLE 1 JAIPUR, JAIPUR

In the result the appeal of the assessee is allowed

ITA 744/JPR/2023[2020-21]Status: DisposedITAT Jaipur25 Jun 2024AY 2020-21
For Appellant: Sh. Tarun Mittal (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 143(3)Section 56(2)Section 56(2)(x)

transfer and payment\nof stamp duty etc. Appellant prays that since payment of part sale consideration\nwas made through banking channels in terms of such agreement cum letter of\n6\nITA No. 744/JP/2023\nNarain Lal Agrawal vs. DCIT\nallotment, assessee is covered by section 56(2)(x) and date of agreement is to be\ntreated as date of sale

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as\nthe sales proceeds from amalgamation and calculated capital gains based on\nsuch figure.\nFrom the detailed submissions placed before me, it is seen that the word\n\"transfer has been inclusively defined in section 2(47) to include exchange,\nrelinquishment and extinguishment of an asset and is not merely restricted to\nsale of capital asset. Since

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)

Price Waterhouse Coopers as\nthe sales proceeds from amalgamation and calculated capital gains based on\nsuch figure.\nFrom the detailed submissions placed before me, it is seen that the word\n\"transfer has been inclusively defined in section 2(47) to include exchange,\nrelinquishment and extinguishment of an asset and is not merely restricted to\nsale of capital asset. Since

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

2,26,24, 12,049/- and delete the disallowance of Rs. 90,55,18,397/-. These grounds are therefore allowed.” 4.3 On the issue of disallowance of Rs. 19,34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed

DEPUTY COMMISISONER OF INCOME TAX , JAIPUR vs. M/S. MAN PRAKSH TALKIES PVT. LTD, JAIPUR

ITA 406/JPR/2018[2008-09]Status: DisposedITAT Jaipur27 Sept 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA. Nos.406 & 407/JP/2018 fu/kZkj.k o"kZ@Assessment Years : 2008-09 & 2009-10 Dy. Commissioner of Income Tax, Circle-02, Jaipur cuke Vs. M/s Man Prakash Talkies Pvt Ltd. Near Yadgar, M. I. Road, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCM 6231 F vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@C.O. Nos.11 & 12/JP/2018 (Arising out of ITA Nos.406 & 407/JP/2018) fu/kZkj.k o"kZ@Assessment

For Appellant: Sh. Sidharth Ranka, Adv. &For Respondent: Sh. Ajay Malik (CIT) &
Section 147

transfer consideration for commercial land (i.e. stock in trade) which is required to be considered for computation as 'Income from Business and Profession'. Out of this consideration, the Fair Market Value of the asset on the date of conversion shall be deducted. In this case, the conversion took place in the 2001-02, as recorded in the Development Agreement dated

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S MAN PRAKASH TALKIES PVT. LTD., JAIPUR

ITA 407/JPR/2018[2009-10]Status: DisposedITAT Jaipur27 Sept 2024AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA. Nos.406 & 407/JP/2018 fu/kZkj.k o"kZ@Assessment Years : 2008-09 & 2009-10 Dy. Commissioner of Income Tax, Circle-02, Jaipur cuke Vs. M/s Man Prakash Talkies Pvt Ltd. Near Yadgar, M. I. Road, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCM 6231 F vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@C.O. Nos.11 & 12/JP/2018 (Arising out of ITA Nos.406 & 407/JP/2018) fu/kZkj.k o"kZ@Assessment

For Appellant: Sh. Sidharth Ranka, Adv. &For Respondent: Sh. Ajay Malik (CIT) &
Section 147

transfer consideration for commercial land (i.e. stock in trade) which is required to be considered for computation as 'Income from Business and Profession'. Out of this consideration, the Fair Market Value of the asset on the date of conversion shall be deducted. In this case, the conversion took place in the 2001-02, as recorded in the Development Agreement dated

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

ITA 666/JPR/2023[2013-14]Status: DisposedITAT Jaipur26 Apr 2024AY 2013-14

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

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

45,000/- claimed on account of payment of Security and Guarantee payment made. The addition so sustained is bad in law and bad on facts. 9. The Id. CIT(A) has erred in sustaining disallowance of Rs. 38,91,000/- on account of application of income claimed for Shala Swasthya Karyakrama incurred. The disallowance so sustained

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

ITA 665/JPR/2023[2009-10]Status: DisposedITAT Jaipur26 Apr 2024AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 665 & 666/JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2009-10 & 2013-14 Jodhpur Development Authority 1, Opposite Railway Hospital, JDA Circle, Jodhpur. cuke Vs. Deputy Commissioner of Income Tax, Exemption, Jodhpur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALJ 0478 P vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Amit Kothari (C.A.) jktLo dh vksjls@Revenue by:

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

45,000/- claimed on account of payment of Security and Guarantee payment made. The addition so sustained is bad in law and bad on facts. 9. The Id. CIT(A) has erred in sustaining disallowance of Rs. 38,91,000/- on account of application of income claimed for Shala Swasthya Karyakrama incurred. The disallowance so sustained

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

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 ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER, AJMER

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

2,26,24, 12,049/- and delete the disallowance of Rs. 90,55,18,397/-. These grounds are therefore allowed.”\n4.3 On the issue of disallowance of Rs. 19,34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed

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

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

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

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

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