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4 results for “transfer pricing”+ Section 151(2)clear

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Key Topics

Section 2639Section 1475Section 143(3)4Section 1484Section 1544Section 92C4Section 1443Addition to Income3Section 2502

M/S. LINDE INDIA LIMITED (FORMERLY BOC INDIA LIMITED),KOLKATA vs. DCIT, CIRCLE 12(1), KOLKATA, KOLKATA

In the result, the appeal of the assessee bearing ITA No

ITA 381/KOL/2017[2012-13]Status: DisposedITAT Kolkata19 Feb 2024AY 2012-13

Bench: Dr. Manish Borad & Shri Anikesh Banerjee

Section 143(3)Section 144CSection 154Section 92CSection 92C(3)

151 of the paper book is reproduced as below: - “37.1. In response to the rebuttal reasons put forward by the assesse, it is to be mentioned here that the companies that have been selected as comparable which are broadly functioning in the gas industry. The major condition for Transfer Pricing Analysis is comparability criteria, thus while price got affected when

MADHUBAN DEALERS PVT. LTD. PRESENTLY KNOWN AS MADHUBAN DEALERS LLP,KOLKATA vs. PCIT-13, KOLKATA

In the result, the appeal of assessee allowed

ITA 273/KOL/2022[2010-11]Status: DisposedITAT Kolkata07 Nov 2023AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 154Section 263Section 68

pricing addition of Rs. 78.97 crores; (ii) Secondly, under the approved scheme of amalgamation, the transferee has assumed the liabilities of the transferor company, including tax liabilities; (iii) Thirdly, the consequence of the scheme of 13 Madhuban Dealers Pvt. Ltd., AY 2010-11 amalgamation approved under Section 394 of the Companies Act 1956 is that the amalgamating company ceased

NAVANSH VINIMAY PVT. LTD.,KOLKATA vs. I.T.O., WARD - 8(2), KOLKATA, KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 724/KOL/2022[2012-2013]Status: DisposedITAT Kolkata30 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

151(1) of the Act. The notice was served on the assessee through email and speed post. In response to the notice u/s 148, the assessee filed its return of income for the A.Y. 2012-13 on 31.03.2019, declaring a total income of Rs. 20,400/-. Subsequently, notice U/S 143(2) and notice u/s 142(1) of the Income

PRAFULLA KUMAR MALAKAR, INCOME TAX OFFICER, WARD-12(1), KOLKATA, KOLKATA vs. KALAWATI INVESTMENTS & TRADING P LTD., KOLKATA

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

ITA 134/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 147Section 148Section 250Section 69

2 & 3 are dismissed. 5.2. Ground No. 4 pertains to the issue of addition of fictitious transactions amounting to Rs.79,04,700/- as unexplained investment u/s 69 of the Act and the same is adjudicated as under: ITA No.: 134/KOL/2025 Assessment Year: 2015-16 Kalawati Investments & Trading P. Ltd. Information was received under Project Falcon from DGIT (Investigation), Mumbai