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34 results for “transfer pricing”+ Section 69Dclear

Sorted by relevance

Jaipur34Rajkot20Bangalore11Delhi11Mumbai3Chennai3Indore2Pune1Surat1

Key Topics

Addition to Income32Section 6829Section 143(3)26Section 153A19Section 145(3)18Section 14315Section 13212Survey u/s 133A10Section 2509

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur14 Feb 2025AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

69D, if such income is not covered under clause (a), the income-tax payable shall be the aggregate of- (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent.; and (ii) the amount of income-tax with which the assessee would have been chargeable

Showing 1–20 of 34 · Page 1 of 2

Section 69B9
Unexplained Cash Credit9
Unexplained Investment5

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 176/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 113/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 114/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 115/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 174/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 175/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj Khandelwal, partner

MILESTONE DEWELLERS PVT. LTD.,JAIPUR vs. ITO WARD 6(2), JAIPUR

In the result, appeal of the assessee is allowed

ITA 565/JPR/2023[2017-18]Status: DisposedITAT Jaipur31 Oct 2023AY 2017-18

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

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 143(3)Section 144BSection 147

transferring proportionate cost of units sold during FY 2013-14 to 2016-17 to the profit & loss account whereas the DVO has estimated the fair cost of entire residential project including the sold units. Hence, the appellant's submission on this count is prima facie correct. 4.1.8 The appellant submitted that the DVO has not granted rebate for self- supervision

DINESH KUMAR TAK,BEAWAR vs. INCOME TAX OFFICER, WARD-2, BEAWAR, BEAWAR

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

ITA 981/JPR/2025[2016-17]Status: DisposedITAT Jaipur18 Sept 2025AY 2016-17
For Appellant: Sh. Sunil Porwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 115BSection 133(6)Section 142(1)Section 143(3)Section 68

price, if ultimately\nthe contract is settled otherwise than by actual delivery or transfer of the\ncommodity, it is a speculative transaction (Juvvi Subbaramaiah & Co. V. CIT\n(1964) 51 ITR 742 (A.P.).\n(d)\nFutures contracts – Transactions in futures contracts like transactions in\nstock and shares when settled otherwise than by actual delivery would be\nspeculative transactions u/sec

MOHAN LAL ASHOK KUMAR SARAF,JAIPUR vs. DCIT CEN CIR 1, JAIPUR

In the result, the appeal of the assessee is allowed as indicated hereinabove

ITA 879/JPR/2024[2017-2018]Status: DisposedITAT Jaipur28 Nov 2024AY 2017-2018
For Appellant: Shri Ankit Totuka, AdvocateFor Respondent: Ms. Alka Gautam, CIT-DR
Section 143(3)Section 68

69D was made taxable 60% was made w.e.f 01.04.2017 after receiving the assent of president on 15.12.2016. The appellant submits that rate of 60% has been wrongly applied in his case by the department as such amendment was made on 15.12.2016 whereas in case of appellant the amount of cash on which the demand has been confirmed under this section

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

transfer of cash to such unexplained advances. If the undisclosed income earned and accumulated over the years is taxed in the year in which it is detected by the Revenue and the same is merely taxed as per normal provisions of the law such an interpretation will place a premium on dishonesty i.e. it tantamounts to rewarding the dishonesty. There

VIRENDRA SINGH RATNAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-2, JAIPUR

In the result, three appeals of the assessee are allowed

ITA 179/JPR/2022[2016-17]Status: DisposedITAT Jaipur01 Jan 2024AY 2016-17

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

For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. Ajay Malik (CIT)
Section 127Section 132Section 133ASection 143(3)Section 153ASection 69A

69D and consequently shall not escape the rigors of applicability of section 115BBE. (iv) Since the addition of Rs. 24,20,366/- has been made by the AO u/s 69A of the Act respectively, therefore the contention of the appellant that the provision of section 115BBE is not applicable is found not acceptable. Infact the addition has been made

VIRENDRA SINGH RATNAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-2, JAIPUR

In the result, three appeals of the assessee are allowed

ITA 181/JPR/2022[2018-19]Status: DisposedITAT Jaipur01 Jan 2024AY 2018-19

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

For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. Ajay Malik (CIT)
Section 127Section 132Section 133ASection 143(3)Section 153ASection 69A

69D and consequently shall not escape the rigors of applicability of section 115BBE. (iv) Since the addition of Rs. 24,20,366/- has been made by the AO u/s 69A of the Act respectively, therefore the contention of the appellant that the provision of section 115BBE is not applicable is found not acceptable. Infact the addition has been made

VIRENDRA SINGH RATNAWAT,JAIPUR vs. ACIT, CENTRAL CIRCLE-2, JAIPUR

In the result, three appeals of the assessee are allowed

ITA 180/JPR/2022[2017-18]Status: DisposedITAT Jaipur01 Jan 2024AY 2017-18

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

For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. Ajay Malik (CIT)
Section 127Section 132Section 133ASection 143(3)Section 153ASection 69A

69D and consequently shall not escape the rigors of applicability of section 115BBE. (iv) Since the addition of Rs. 24,20,366/- has been made by the AO u/s 69A of the Act respectively, therefore the contention of the appellant that the provision of section 115BBE is not applicable is found not acceptable. Infact the addition has been made

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

69D etc. of the Act. Such unexplained funds are the unexplained money with the appellant and is taxable u/s 69A of the Act irrespective of whether the books of accounts are in existence or not as it is undisputed that the funds were received by the appellant and the same are unexplained. It is held accordingly. This also distinguishes

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

69D etc. of the Act. Such unexplained funds are the unexplained money with the appellant and is taxable u/s 69A of the Act irrespective of whether the books of accounts are in existence or not as it is undisputed that the funds were received by the appellant and the same are unexplained. It is held accordingly. This also distinguishes

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

69D etc. of the Act. Such unexplained funds are the unexplained money with the appellant and is taxable u/s 69A of the Act irrespective of whether the books of accounts are in existence or not as it is undisputed that the funds were received by the appellant and the same are unexplained. It is held accordingly. This also distinguishes

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

69D etc. of the Act. Such unexplained funds are the unexplained money with the appellant and is taxable u/s 69A of the Act irrespective of whether the books of accounts are in existence or not as it is undisputed that the funds were received by the appellant and the same are unexplained. It is held accordingly. This also distinguishes

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

69D etc. of the Act. Such unexplained funds are the unexplained money with the appellant and is taxable u/s 69A of the Act irrespective of whether the books of accounts are in existence or not as it is undisputed that the funds were received by the appellant and the same are unexplained. It is held accordingly. This also distinguishes

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

price received by the seller of the goods for the acquisition of which it has already incurred the cost. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. (4) Manmohan Sadhani Vs. Commissioner of Income Tax, (2008) 304 ITR 0052 – Hon’ble M.P. HighCourt In this