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24 results for “transfer pricing”+ Section 12(1)(ac)clear

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Key Topics

Section 14835Section 14734Addition to Income23Condonation of Delay20Section 115J18Section 69A17Section 13217Section 14A8Section 50C

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 372/KOL/2021[2014-15]Status: DisposedITAT Kolkata17 Sept 2024AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR
Section 250Section 43(6)Section 50CSection 50C(2)Section 928

1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having

Showing 1–20 of 24 · Page 1 of 2

8
Section 2505
Set Off of Losses2
Disallowance2

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 373/KOL/2021[2015-16]Status: DisposedITAT Kolkata17 Sept 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR
Section 250Section 43(6)Section 50CSection 50C(2)Section 928

1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having

NORMURA RESEARCH INSTITURE FINANCIAL TECHNOLOGIES INDIA PRIVATE LIMITED,KOLKATA vs. ACIT,CIRCLE-2(2), KOL, KOLKATA

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

ITA 204/KOL/2017[2012-13]Status: DisposedITAT Kolkata09 Feb 2023AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri J. P. Khaitan, Sr. Counsel & ShriFor Respondent: Shri Amal Kamat, CIT, DR
Section 115JSection 143(3)Section 144CSection 144C(5)

12 in ITA No. 284/Kol/2016 dated 26.10.2018. On perusal of the said order, it is noted that these issues are dealt with vide para 18, which is extracted below: “18. The Ground No. 26 raised by the assessee is with regard to the action of the ld AO in adding back the disallowance conceived

MEGAPODE VYAPAAR PVT. LTD.,KOLKATA vs. D.C.I.T., CENTRAL CIRCLE - 1(2), KOLKATA, KOLKATA

In the result, ITA No. 98/KOL/2023 is allowed for statistical purposes

ITA 98/KOL/2023[2012-2013]Status: DisposedITAT Kolkata12 Mar 2024AY 2012-2013

Bench: Sri Rajesh Kumar & Sri Anikesh Banerjee

Section 144Section 250Section 43(5)

1,32,01,291/- earned by the assesses. Loss in Trading in currency derivative is speculative loss as per definition of Speculative transaction provided in section 43(5) of the I. T. Act, which defines speculative transaction ds under Section 43(5) of the I. T. Act: “Speculative transaction” means a transaction in which a contract for the purchase

BALHANUMAN COMMODEAL PVT. LTD.,KOLKATA vs. ITO, WARD-5(4), KOLKATA

ITA 116/KOL/2024[2012-13]Status: DisposedITAT Kolkata03 Oct 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri Vineet Kumar, Addl. CIT, Sr. DR
Section 131Section 143(2)Section 143(3)Section 14ASection 250Section 68

12 Balhanuman Commodeal Pvt. Ltd. : AY: 2012-13 9. Ground No 3 is general in nature and does not require adjudication. 10. Resultantly, the appeal preferred by the appellant is DISMISSED. 7. In the course of the appeal, the assessee has submitted as under: Kindly refer to the above mentioned appeal fixed for hearing on 15.05.2024 before

AASHIRWAD VINCOM PVT. LTD.,KOLKATA vs. I.T.O., WARD - 9(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed for statistical purposes

ITA 744/KOL/2022[2013-2014]Status: DisposedITAT Kolkata18 Oct 2023AY 2013-2014

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2013-14

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Abhijit Kundu, CIT, DR
Section 143(3)Section 14ASection 43(5)(d)Section 73

transfer of the commodity or scrips: Provided that for the purposes of this clause— (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual deli- very of goods manufactured

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1703/KOL/2025[2020-21]Status: DisposedITAT Kolkata09 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is reproduced as under, 22. in the light of the information received from DGIT (Investigation), Mumbai, and the evidence filed by the assessee claiming that purchases from the aforesaid four parties were genuine, the AO concluded that the purchases from the four parties were not genuine. This conclusion

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1699/KOL/2025[2015-16]Status: DisposedITAT Kolkata09 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is reproduced as under, 22. in the light of the information received from DGIT (Investigation), Mumbai, and the evidence filed by the assessee claiming that purchases from the aforesaid four parties were genuine, the AO concluded that the purchases from the four parties were not genuine. This conclusion

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the revenue is dismissed

ITA 1596/KOL/2025[2016-17]Status: DisposedITAT Kolkata09 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is reproduced as under, 22. in the light of the information received from DGIT (Investigation), Mumbai, and the evidence filed by the assessee claiming that purchases from the aforesaid four parties were genuine, the AO concluded that the purchases from the four parties were not genuine. This conclusion

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

ITA 1702/KOL/2025[2018-19]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is reproduced as under, 22. in the light of the information received from DGIT (Investigation), Mumbai, and the evidence filed by the assessee claiming that purchases from the aforesaid four parties were genuine, the AO concluded that the purchases from the four parties were not genuine. This conclusion

GOPAL & SONS HUF,KOLKATA vs. I.T.O., WARD - 32(1), KOLKATA, KOLKATA

The appeal of the revenue is dismissed

ITA 1701/KOL/2024[2006-2007]Status: DisposedITAT Kolkata08 Jan 2025AY 2006-2007

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is reproduced as under, 22. in the light of the information received from DGIT (Investigation), Mumbai, and the evidence filed by the assessee claiming that purchases from the aforesaid four parties were genuine, the AO concluded that the purchases from the four parties were not genuine. This conclusion

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED , PATNA

The appeal of the Revenue is dismissed

ITA 1595/KOL/2025[2015-16]Status: DisposedITAT Kolkata09 Dec 2025AY 2015-16
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

ITA 1704/KOL/2025[2023-24]Status: DisposedITAT Kolkata09 Dec 2025AY 2023-24
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

ACIT, CIRCLE - 6(2), KOLKATA vs. M/S. NAGREEKA SYNTHETICS PVT. LTD., KOLKATA

In the result, the appeal of the revenue is allowed for statistical purposes and the cross-objection by the assessee are dismissed

ITA 427/KOL/2019[2009-10]Status: DisposedITAT Kolkata09 Nov 2023AY 2009-10

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 427/Kol/2019 Assessment Year: 2009-10 Asst. Commissioner Of Income Tax, M/S. Nagreeka Synthetics Pvt. Ltd. Circle-6(2), Kolkata Vs 6Th Floor, Jain Chamber 18, R.N. Mukherjee Road Kolkata - 700001 [Pan : Aaacn8691D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 19/Kol/2021 Assessment Year: 2009-10 M/S. Nagreeka Synthetics Pvt. Ltd. Asst. Commissioner Of Income 6Th Floor, Jain Chamber Vs Tax, Circle-6(2), Kolkata 18, R.N. Mukherjee Road Kolkata - 700001 [Pan : Aaacn8691D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.D. Verma, Advocate Revenue By : Shri Abhijit Kundu, Cit D/R सुनवाई क" तारीख/Date Of Hearing : 05/09/2023 घोषणा क" तारीख /Date Of Pronouncement: 09/11/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)- 4, Kolkata (Hereinafter The “Ld. Cit(A)”) Dt. 21/06/2018, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2009- 10. The Assessee Has Filed A Cross-Objection Being C.O. No. 19/Kol/2021. 2. The Registry Has Pointed Out That There Is A Delay Of 965 Days In Filing The Cross-Objection By The Assessee. The Assessee Has Filed A 2

For Appellant: Shri S.D. Verma, AdvocateFor Respondent: Shri Abhijit Kundu, CIT D/R
Section 143(1)Section 143(3)Section 148Section 2(22)(e)Section 250Section 73

transfer of the commodity or scrips Provided that for the purposes of this clause— (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

DCIT, CENTRAL CIRCLE- 4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

ITA 1700/KOL/2025[2016-17]Status: DisposedITAT Kolkata09 Dec 2025AY 2016-17
For Appellant: Shri Manish Rastogi, ARFor Respondent: Shri Pankaj Pandey, DR
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

ITA 1597/KOL/2025[2017-18]Status: DisposedITAT Kolkata09 Dec 2025AY 2017-18
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

ITA 1397/KOL/2025[2018-2019]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-2019
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

BALMUKUND SPONGE & IRON PVT. LTD.,,PATNA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

ITA 1398/KOL/2025[2023-2024]Status: DisposedITAT Kolkata09 Dec 2025AY 2023-2024
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

BALMUKUND CEMENT & ROOFINGS PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

The appeal of the Revenue is dismissed

ITA 1399/KOL/2025[2023-2024]Status: DisposedITAT Kolkata09 Dec 2025AY 2023-2024
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED, KOLKATA

The appeal of the Revenue is dismissed

ITA 1701/KOL/2025[2017-18]Status: DisposedITAT Kolkata09 Dec 2025AY 2017-18
Section 115JSection 132Section 147Section 148Section 69A

AC was the possible view, relevant portion of the decision in verbatim is\nreproduced as under,\n22. in the light of the information received from DGIT (Investigation), Mumbai, and the\nevidence filed by the assessee claiming that purchases from the aforesaid four parties\nwere genuine, the AO concluded that the purchases from the four parties were not\ngenuine. This conclusion