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18 results for “transfer pricing”+ Section 144Bclear

Sorted by relevance

Delhi244Mumbai176Hyderabad93Bangalore60Pune50Ahmedabad31Jaipur31Chennai24Chandigarh19Kolkata18Surat16Rajkot15Visakhapatnam10Dehradun10Indore9Cochin4Nagpur3Guwahati2Lucknow2Raipur2Agra1Cuttack1Amritsar1

Key Topics

Section 143(3)28Section 26320Addition to Income11Section 14A10Section 92C10Section 6810Transfer Pricing9Section 144C(5)8Section 270A

M/S. TEGA INDUSTRIES LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA

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

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2020-21 dated 24.07.2024, which has been passed as per the directions of the Dispute Resolution Panel-2, New Delhi u/s 144C(5) of the Act, dated 11.06.2024. 2. The assessee is in appeal raising the following grounds of appeal: “1. Order

M/S TEGA INDUSTRIES LTD.,KOLKATA vs. DCIT, CIRCLE-11(1), KOLKATA

7
Section 43C7
Disallowance6
Comparables/TP5

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

ITA 2597/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 144BSection 144C(5)Section 244ASection 92BSection 92CSection 92C(3)

Section 144B of the Act and read with the order passed by the Ld. Transfer Pricing Officer (TPO'), under section

JAMSHEDPUR CONTINUOUS ANNEALING & PROCESSING COMPANY PVT. LTD.,KOLKATA vs. ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, both the appeals filed by the assessee in ITA No

ITA 295/KOL/2022[2018-19]Status: DisposedITAT Kolkata26 Feb 2024AY 2018-19

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 144C(5)Section 154Section 270A

144B of the Income Tax Act (brevity the Act) dated 25/10/2021in pursuant to the directions of Dispute Resolution Panel-2 (in brevity DRP), New Delhi, dated 13/09/2021 issued U/s 144C(5) of the Act pertains to Assessment years2017-18 & 2018-19. 2. At the outset both the appeals have the same nature and fact and have a common factual issue

JAMSHEDPUR CONTINUOUS ANNEALING & PROCESSING COMPANY PRIVATE LIMITED,KOLKATA vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, both the appeals filed by the assessee in ITA No

ITA 595/KOL/2021[2017-18]Status: DisposedITAT Kolkata26 Feb 2024AY 2017-18

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 144C(5)Section 154Section 270A

144B of the Income Tax Act (brevity the Act) dated 25/10/2021in pursuant to the directions of Dispute Resolution Panel-2 (in brevity DRP), New Delhi, dated 13/09/2021 issued U/s 144C(5) of the Act pertains to Assessment years2017-18 & 2018-19. 2. At the outset both the appeals have the same nature and fact and have a common factual issue

EREVMAX TECHNOLOGIES PVT. LTD.,KOLKATA vs. D.C.I.T./A.C.I.T., TP-1, , KOLKATA

Appeal of the assessee is partly allowed for statistical purposes

ITA 2551/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: Us In The Paper Book)

Section 143(3)

144B of the Income Tax Act, 1961 (hereafter “the Act”). In this case, the points of dispute resolve around Arm’s Length Adjustment (ALP) of price with respect to export of software and IT services to Associated Enterprise (AE) located in USA, at Rs. 1,76,78,365/-, and an addition in respect of bad debts

MECLEOD RUSSEL INDIA LTD.,KOLKATA vs. A.C.I.T., CIRCLE - 4(1), KOLKATA, KOLKATA

The appeals of the assessee are partly allowed

ITA 454/KOL/2022[2017-2018]Status: DisposedITAT Kolkata17 Jun 2025AY 2017-2018

Bench: the due date of filing of return u/s 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

144B of the Income Tax Act, 1961 (hereafter “the Act”), after the Ld. Dispute Mecleod Russel India Ltd. Resolution Panel (hereafter “the Ld. DRP”) orders dated 24.06.2022 in both the cases. The assessee is aggrieved with the impugned orders and has raised the following grounds of appeal as under: “1. The Learned Dispute Resolution Panel (DRP) erred on facts

MCLEOD RUSSEL INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE-4(1), KOLKATA, KOLKATA

The appeals of the assessee are partly allowed

ITA 458/KOL/2022[2018-2019]Status: DisposedITAT Kolkata17 Jun 2025AY 2018-2019

Bench: the due date of filing of return under Section 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

144B of the Income Tax Act, 1961 (hereafter “the Act”), after the Ld. Dispute Mecleod Russel India Ltd. Resolution Panel (hereafter “the Ld. DRP”) orders dated 24.06.2022 in both the cases. The assessee is aggrieved with the impugned orders and has raised the following grounds of appeal as under: “1. The Learned Dispute Resolution Panel (DRP) erred on facts

TATA CONSUMER PRODUCTS LIMITED (SUCCESSOR OF TATA COFFEE LTD.),KOLKATA vs. A.C.I.T., CIRCLE - 4(1), KOLKATA

Appeal of the assessee is partly allowed

ITA 2636/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 144Section 144BSection 144C(5)Section 153Section 438Section 43BSection 80MSection 928Section 92B

144B of the Income Tax Act, 1961 (hereafter “the Act”), dated 29.10.2024. 1.1 In this case, there are several issues which require to be adjudicated. We may briefly mention then as under: (a) Transfer Pricing adjustment on account of Corporate Guarantee (CG). The Ld. Transfer Pricing Officer) (TPO) has worked out a CG @ 1%, whereas 2 Tata Consumer Products Limited

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2), GANGTOK, GANGTOK SIKKIM vs. SIKKIM STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED , GANGTOK SIKKIM

In the result, the appeal filed by the Revenue is dismissed

ITA 1711/KOL/2024[2020-21]Status: DisposedITAT Kolkata29 Apr 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 274Section 40Section 80GSection 80PSection 80P(2)(d)

144B of the Act on 08.09.2022, wherein total income was determined at Rs. 1,61,28,130/- after making additions/disallowance of (i) sum of Rs. 5,41,897/- disallowed under section 40(a)(ia) of the Act towards payments made without deducting I.T.A. No.: 1711/KOL/2024 Assessment Year: 2020-21 Sikkim State Cooperative Supply and Marketing Federation Limited. TDS; (ii) disallowance

EIH LIMITED ,KOLKATA vs. DCIT, NFAC, DELHI

In the result, both the appeals of the assessee are partly allowed

ITA 181/KOL/2022[2017-18]Status: DisposedITAT Kolkata18 Nov 2024AY 2017-18

Bench: SHRI RAJPAL YADAV, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 143(3)Section 14ASection 92C

144B of the Income Tax Act, 1961 (in short “the Act”) dated 28.02.2022, through which the following additions (as are relevant for this adjudication) were made: I.T.A. Nos.181 & 498/Kol/2022 EIH Limited (i) TP Adjustment on account of Corporate Guarantee (hereafter CG) of Rs. 63,57,591/-. (ii) Disallowance u/s 14A of the Act r.w. Rule

EIH LIMITED,KOLKATA vs. D.C.I.T., INCOME TAX DEPARTMENT, NFAC, DELHI, KOLKATA

In the result, both the appeals of the assessee are partly allowed

ITA 498/KOL/2022[2018-2019]Status: DisposedITAT Kolkata18 Nov 2024AY 2018-2019

Bench: SHRI RAJPAL YADAV, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 115JSection 143(3)Section 14ASection 92C

144B of the Income Tax Act, 1961 (in short “the Act”) dated 28.02.2022, through which the following additions (as are relevant for this adjudication) were made: I.T.A. Nos.181 & 498/Kol/2022 EIH Limited (i) TP Adjustment on account of Corporate Guarantee (hereafter CG) of Rs. 63,57,591/-. (ii) Disallowance u/s 14A of the Act r.w. Rule

SUGAM GRIHA NIRMAAN LIMITED,KOLKATA vs. D.C.I.T., CENTRAL CIRCLE - 4(3), , KOLKATA

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

ITA 1665/KOL/2024[2018-2019]Status: DisposedITAT Kolkata09 May 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 270A(1)Section 43C

transfer of assets for which the Auditor in the audit report mentioned that the flats were sold for a price less than the value adopted by the authority of the State Government. The Ld. AO also found that there were no supporting evidences about the value adopted by the State Government at the time of registration and the ledger accounts

SKYBRIDGE REAL ESTATES LLP,KOLKATA vs. D.C.I.T., CIRCLE - 34, KOLKATA, KOLKATA

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

ITA 1849/KOL/2024[2018-2019]Status: DisposedITAT Kolkata02 Dec 2024AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Skybridge Real Estates Llp Dcit, Circle -34, 24, Hemant Basu Sarani, Aaykar Bhavan Poorva, 110, Mangalam-A, 5Th Floor, Room Shanti Pally, E.M. Bypass, Vs. No.507, Kolkata-700001, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Acvfs7139R Assessee By : Shri N.S. Saini, Ar Revenue By : Ms. Ruchika Sharma, Dr Date Of Hearing: 21.11.2024 Date Of Pronouncement : 02.12.2024

For Appellant: Shri N.S. Saini, ARFor Respondent: Ms. Ruchika Sharma, DR
Section 10(38)Section 143(3)Section 144BSection 28

144B of the Act. 04. In the appellate proceedings, the ld. CIT (A) simply affirmed the order of ld. AO. 05. After hearing the rival contentions and perusing the materials available on record, we note that the assessee is in the business of investment and trading in shares, securities and derivatives besides doing the business of general commission agent

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1037/KOL/2025[2015-2016]Status: DisposedITAT Kolkata16 Oct 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

price. The ld. CIT (A) also noted that the investors company were received funds from some other companies and thus providing to the assessee company without ITA No.1035 to 1038/KOL/2025 Samrat Finvestors Private Limited AYs: 2012-13, 2014-15 to 2016-17 having their own resources or operating income etc. the ld. CIT (A) in Para no.6.2.2 noted that

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. ITO, WARD 5(2) (NOW DCIT, CENT.CIR. 4(2)), KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1035/KOL/2025[2012-2013]Status: DisposedITAT Kolkata16 Oct 2025AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

price. The ld. CIT (A) also noted that the investors company were received funds from some other companies and thus providing to the assessee company without ITA No.1035 to 1038/KOL/2025 Samrat Finvestors Private Limited AYs: 2012-13, 2014-15 to 2016-17 having their own resources or operating income etc. the ld. CIT (A) in Para no.6.2.2 noted that

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1036/KOL/2025[2014-2015]Status: DisposedITAT Kolkata16 Oct 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

price. The ld. CIT (A) also noted that the investors company were received funds from some other companies and thus providing to the assessee company without ITA No.1035 to 1038/KOL/2025 Samrat Finvestors Private Limited AYs: 2012-13, 2014-15 to 2016-17 having their own resources or operating income etc. the ld. CIT (A) in Para no.6.2.2 noted that

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1038/KOL/2025[2016-2017]Status: DisposedITAT Kolkata16 Oct 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

price. The ld. CIT (A) also noted that the investors company were received funds from some other companies and thus providing to the assessee company without ITA No.1035 to 1038/KOL/2025 Samrat Finvestors Private Limited AYs: 2012-13, 2014-15 to 2016-17 having their own resources or operating income etc. the ld. CIT (A) in Para no.6.2.2 noted that

INCOME TAX OFFICER, WARD-9(1), KOLKATA, KOLKATA vs. SUR MANGAL HOLDINGS PRIVATE LIMITED, KOLKATA

In the result, appeal of the revenue stands dismissed

ITA 1437/KOL/2024[2017-18]Status: DisposedITAT Kolkata22 Apr 2025AY 2017-18

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

Section 147Section 148(1)Section 68Section 69

144B of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) by Assessment Unit, Income Tax Department dated 23.05.2023. 2. The assessee has raised the following grounds of appeal: “1. Whether on the fact and in the circumstances of the case, the Ld. CIT(A) erred in deleting the addition made under bogus loss amounting to Rs.75