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19 results for “transfer pricing”+ Section 920clear

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Key Topics

Addition to Income18Section 143(3)14Section 153C10Survey u/s 133A9Section 145(3)7Section 1436Section 2505Section 685Section 56(2)(viib)

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and disposed off in light of aforesaid directions

ITA 97/JPR/2021[2016-17]Status: DisposedITAT Jaipur07 Feb 2022AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavvaibhav Global Limited, Deputy Commissioner Of बनाम Jaipur. Income Tax, Central Circle-4, Jaipur. "थायी लेखा सं./Pan No: Aaacv4679F

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri B.K. Gupta, Pr.CIT
Section 143(3)Section 144C(13)Section 234ASection 92CSection 92D

section 144C(13) of the Act was passed by the Assessing officer on 13.11.2019 wherein adjustment on account of transfer pricing as proposed by the Transfer Pricing Officer was made and the assessed income was determined at Rs.57,36,47,429/-. 3. Against the draft assessment order, the assessee filed its objections before the Dispute Resolution Panel and after considering

5
Section 40A(3)5
Disallowance3
Penny Stock3

HOLIDAY TRIANGLE TRAVEL PRIVATE LIMITED,GURGAON vs. INCOME TAX OFFICER, JAIPUR

In the result, appeal of the assessee is allowed

ITA 67/JPR/2024[2014-15]Status: DisposedITAT Jaipur20 Jan 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Dilip Shivpuri, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 142(1)Section 143(2)Section 250Section 56(2)(viib)

920/- under section 56(2)(viib) of the Income Tax Act, 1961 as its Income from other sources. Being aggrieved by the order of the AO, the assessee preferred appeal before the ld. CIT (A). The ld.CIT (A) sustained the action of the AO by holding that (1) The Explanation (a)(ii) of sub section (viib) of section

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

ITA 234/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

transfer\npricing orders wherein downward adjustments were made to the price\npaid for the equipment imported by the AE. The Assessee had filed an\nappeal to this Tribunal against the appellate order for Assessment Year\n2013-14 (arising from the assessment under Section 143(3) and the TPO\norder). This appeal was disposed in RKM POWERGEN PRIVATE\nLIMITED

VIRENDRA PRAKASH SHARMA,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 286/JPR/2025[2020-21]Status: DisposedITAT Jaipur16 Jul 2025AY 2020-21
For Appellant: Shri Rajeev Sogani, CA &For Respondent: Smt. Runi Pal, CIT (Th. VC)
Section 132Section 143(3)Section 144C(13)Section 144C(5)Section 153CSection 69

transfer of funds was demonstrated by Id. AO which facts were not in\ndispute. In the present case, the lower authorities have arbitrarily presumed—\nwithout any direct or indirect evidence, basis, or corroboration—that a vague and\nrough entry found during search pertains specifically to the assessee. Such\ninference is wholly unjustified and devoid of any factual or legal basis

M/S VIJAYETA BUILDCON PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the ground of the assessee’s appeal is allowed

ITA 980/JPR/2018[2007-08]Status: DisposedITAT Jaipur27 Oct 2020AY 2007-08
For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. B. K. Gupta (CIT)
Section 153ASection 253(5)Section 40A(3)

transfer of ownership and management of the assessee company, would be handled by the erstwhile management group. It was further submitted that Sh. Jagdish Narain Khandelwal an employee of the erstwhile management who looks after the income tax matters collected the duly filled Form No. 36 and other papers from the Counsel and he handed over the said papers

A DAGA ROYAL ARTS,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1065/JPR/2016[2013-14]Status: DisposedITAT Jaipur15 May 2018AY 2013-14
For Appellant: Shri Rajeev Sogani (C.A)For Respondent: Shri J. C. Kulhari (JCIT)
Section 40A(3)

920/- were made in cheque to various persons, and Rs. 8,15,700/- and Rs. 6,84,296/- were paid in cash towards stamp duty and Court fee respectively. 3. During the course of assessment proceedings, a show-cause notice was issued to the assessee as to why the purchases made in cash should not be disallowed

PRABHA AGARWAL,JAIPUR vs. DCIT CIRCLE -6 , JAIPUR

ITA 163/JPR/2021[2014-15]Status: DisposedITAT Jaipur11 Oct 2022AY 2014-15

Bench: The Date Of Appeal Hearing.

For Appellant: Shri S.L. Jain (Advocate)For Respondent: Smt. Monisha Choudhary (JCIT)
Section 10(38)Section 132(4)Section 134ASection 143(1)Section 147Section 148Section 151Section 250Section 69C

920/- claiming exempt Long Term Capital Gain of Rs. 21,48,870/- under section 10(38) of the Income Tax Act, 1961. The return was processed under Smt. Prabha Agarwal, Jaipur. section 143(1) of the Income Tax Act, 1961 on 24.03.2016 at declared income. Later on, information was received from Directorate of Investigation that an organized racket of generating

PRABHA AGARWAL,JAIPUR vs. ACIT/DCIT CIR-6, JAIPUR

ITA 164/JPR/2021[2015-16]Status: DisposedITAT Jaipur11 Oct 2022AY 2015-16

Bench: The Date Of Appeal Hearing.

For Appellant: Shri S.L. Jain (Advocate)For Respondent: Smt. Monisha Choudhary (JCIT)
Section 10(38)Section 132(4)Section 134ASection 143(1)Section 147Section 148Section 151Section 250Section 69C

920/- claiming exempt Long Term Capital Gain of Rs. 21,48,870/- under section 10(38) of the Income Tax Act, 1961. The return was processed under Smt. Prabha Agarwal, Jaipur. section 143(1) of the Income Tax Act, 1961 on 24.03.2016 at declared income. Later on, information was received from Directorate of Investigation that an organized racket of generating

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. NARESH KUMAR GUPTA, SRIGANGANAGAR

In the results the appeal of the revenue stands dismissed and the

ITA 458/JPR/2024[2014-15]Status: DisposedITAT Jaipur28 Nov 2024AY 2014-15

Bench: Him The Order Passed Under Section 143(3) Of The Income Tax Act, [ For Short “Act” ] By The Acit, Circle, Sri Ganganagar [

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Ms. Alka Gautam (CIT) (V.H.)
Section 143(3)Section 14ASection 36(1)(iii)

price variation was more than the range of thousands rupee per quintal per day. Various issues relating to stock movements as well as negative stock or excess closing stock raised arises mainly due to the reason that stock report made based on the impounded record by the ld. AO was on the basis of invoice date (which is actually also

DCIT, JAIPUR vs. AMRAPALI JEWELS PVT. LTD. , JAIPUR

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

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

pricing etc. and item quantitative control on staff. In the tax audit report no quantitative details are mentioned. This list is in the nature of undisclosed records or incriminating material unearthed during the survey. (xiv) The appellant has claimed that the valuation should have been by the official valuers for each item separately of the taking into consideration the exact

INCOME TAX OFFICER, JAIPUR vs. RENU AGARWAL, JAIPUR

In the result, appeal of the Revenue is dismissed

ITA 502/JPR/2025[2015-16]Status: DisposedITAT Jaipur30 Sept 2025AY 2015-16
For Appellant: Shri Shailesh Mantri, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr.DR
Section 143(3)Section 250Section 68

transferred in his name in the register of EEL. In support of his claim notice also submitted the copy of relevant pages of register of EEL showing that his name was entered as a member in the register of EEL on January 15, 2011. Noticee also submit6ted the shareholding patterns filed by the company with BSE for the quarter ended

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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)

price escalation and making charges which in no case could be as high as applied by ld.AO at 24.14%. It is settled proposition of law M/s Royal Jewellers vs. DCIT that once the books are rejected, only recourse available with an AO is to estimate the income. In that situation it is the duty of AO that such estimations should

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

transferred via cheques or bank transfers, ensuring a transparent\naudit trail. Importantly, there were no outstanding balances associated\nwith these transactions at any point, indicating that loans were duly\nrepaid in subsequent years. This factor is pivotal in establishing the\ngenuneness of the transactions, as it reflects a legitimate business\npractice rather than an attempt to camouflage undisclosed income

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Section 194 and 200 were challenged. It was noted in P. RatnakarRao and others V. Govt. Of A.P. and others (1996 (5) SCC 359) that the discretion given under Section 200(1) to the State Government to prescribe maximum rates for compounding the offence is not unguided, uncanalised and arbitrary. It was, inter alia, held as follows: ……………….. ………………. It is indisputable