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19 results for “transfer pricing”+ Section 36(1)(via)clear

Sorted by relevance

Mumbai224Delhi168Chandigarh65Bangalore62Jaipur60Chennai59Ahmedabad43Hyderabad34Kolkata19Pune16Guwahati16Indore12Nagpur11Cuttack8Amritsar4Rajkot3Surat3Cochin2Visakhapatnam1Lucknow1Jodhpur1

Key Topics

Section 14734Section 14834Section 115J19Section 69A17Section 13217Addition to Income17Condonation of Delay17Section 14A6Section 143(3)

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

transfer pricing adjustment of Rs.1,40,38,728/-made in respect of Corporate Guarantees provided by the appellant is vitiated by an error in law and fact and is therefore liable to be deleted. 3. For that the Assessing Officer erred in law and on facts in mechanically making further disallowance u/s 14A of Rs 5,17,964/- by invoking

2
Section 36(1)(va)2
Transfer Pricing2
Double Taxation/DTAA2

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

transfer pricing adjustment of Rs.1,40,38,728/-made in respect of Corporate Guarantees provided by the appellant is vitiated by an error in law and fact and is therefore liable to be deleted. 3. For that the Assessing Officer erred in law and on facts in mechanically making further disallowance u/s 14A of Rs 5,17,964/- by invoking

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

The appeal of the Revenue is dismissed

ITA 1396/KOL/2025[2017-2018]Status: DisposedITAT Kolkata09 Dec 2025AY 2017-2018
Section 115JSection 132Section 147Section 148Section 69A

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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 1598/KOL/2025[2018-19]Status: DisposedITAT Kolkata09 Dec 2025AY 2018-19
Section 115JSection 132Section 147Section 148Section 69A

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

DCIT CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND LEASE FIN PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

ITA 1759/KOL/2025[2020-21]Status: DisposedITAT Kolkata09 Dec 2025AY 2020-21
Section 115JSection 132Section 147Section 148Section 69A

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

The appeal of the Revenue is dismissed

ITA 1395/KOL/2025[2015-2016]Status: DisposedITAT Kolkata09 Dec 2025AY 2015-2016
Section 115JSection 132Section 147Section 148Section 69A

via the network of shell companies.\nThe entry operator clearly explained the circular trading of bogus purchases and sales\nthrough bank guarantees/LC. The entry provider is giving the purchase entry as well\nthe sales entry also. As a result, the entire circuit of the bogus sale is started and\nended at the entry operator only However, the assessee had already

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

via the network of shell companies. The entry operator clearly explained the circular trading of bogus purchases and sales through bank guarantees/LC. The entry provider is giving the purchase entry as well the sales entry also. As a result, the entire circuit of the bogus sale is started and ended at the entry operator only However, the assessee had already

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

via the network of shell companies. The entry operator clearly explained the circular trading of bogus purchases and sales through bank guarantees/LC. The entry provider is giving the purchase entry as well the sales entry also. As a result, the entire circuit of the bogus sale is started and ended at the entry operator only However, the assessee had already

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

via the network of shell companies. The entry operator clearly explained the circular trading of bogus purchases and sales through bank guarantees/LC. The entry provider is giving the purchase entry as well the sales entry also. As a result, the entire circuit of the bogus sale is started and ended at the entry operator only However, the assessee had already

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

via the network of shell companies. The entry operator clearly explained the circular trading of bogus purchases and sales through bank guarantees/LC. The entry provider is giving the purchase entry as well the sales entry also. As a result, the entire circuit of the bogus sale is started and ended at the entry operator only However, the assessee had already

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

via the network of shell companies. The entry operator clearly explained the circular trading of bogus purchases and sales through bank guarantees/LC. The entry provider is giving the purchase entry as well the sales entry also. As a result, the entire circuit of the bogus sale is started and ended at the entry operator only However, the assessee had already