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26 results for “transfer pricing”+ Section 69Aclear

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Key Topics

Section 14735Section 14834Addition to Income25Section 69A19Section 115J19Condonation of Delay19Section 13218Section 143(3)9Section 14A8Section 80I

D.C.I.T.,CIRCLE-8(2), KOLKATA vs. M/S R.P.COMTRADE LTD., KOLKATA

In the result, both the appeals filed by the revenue are dismissed

ITA 208/KOL/2020[2013-14]Status: DisposedITAT Kolkata20 May 2022AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manish Boradi.T.A. No. 207/Kol/2020 Assessment Year: 2012-13 &

For Appellant: Shri Akkal Dudhewala, A/RFor Respondent: Shri G.H. Sema, Addl. CIT, D/R
Section 143(3)Section 250Section 69ASection 92C

transfer pricing addition of Rs.5,73,75,965/- made by the TPO in relation to the purchases made from AE, PLG Singapore. After considering the rival submissions, it is observed that the issue involved in this ground is identical to the Ground Nos. 1 to 3 of Revenue’s appeal in A.Y. 2012-13. Following our conclusion drawn

Showing 1–20 of 26 · Page 1 of 2

6
Disallowance4
Cash Deposit3

D.C.I.T.,CIRCLE-8(2), KOLKATA vs. M/S R.P.COMTRADE LTD., KOLKATA

In the result, both the appeals filed by the revenue are dismissed

ITA 207/KOL/2020[2012-13]Status: DisposedITAT Kolkata20 May 2022AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manish Boradi.T.A. No. 207/Kol/2020 Assessment Year: 2012-13 &

For Appellant: Shri Akkal Dudhewala, A/RFor Respondent: Shri G.H. Sema, Addl. CIT, D/R
Section 143(3)Section 250Section 69ASection 92C

transfer pricing addition of Rs.5,73,75,965/- made by the TPO in relation to the purchases made from AE, PLG Singapore. After considering the rival submissions, it is observed that the issue involved in this ground is identical to the Ground Nos. 1 to 3 of Revenue’s appeal in A.Y. 2012-13. Following our conclusion drawn

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

M/S ADHUNIK INFRASTRUCTURE PVT. LTD.,KOLKATA vs. JCIT, RG-10, KOLKATA, KOLKATA

In the result, the appeal of the assessee is partly allowed

ITA 1281/KOL/2015[2010-2011]Status: DisposedITAT Kolkata23 May 2018AY 2010-2011

Bench: Hon’Ble Shri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No.1281 /Kol/2015 Assessment Year : 2010-11

For Appellant: Shri Miraj D.Shah, ARFor Respondent: Shri Saurabh Kumar, Addl. CIT, Sr.Dr
Section 143(3)Section 80I

69a [(vi ) any undertaking carrying on the business of laying and operating a cross-country natural gas distribution network, including pipelines and storage facilities being an integral part of such network, which fulfils the following conditions, namely:— (a ) it is owned by a company registered in India or by a consortium of such companies or by an authority

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

transferred the title of ownership to the lessee and claimed depreciation under section 32 of the Act on the said leased assets being the legal owner. 18. FOR THAT the DRP erred in applying the decision of the jurisdictional tribunal in the case of Phillips India and the Delhi High Court in the case of Rio Tinto, when both these

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

transferred the title of ownership to the lessee and claimed depreciation under section 32 of the Act on the said leased assets being the legal owner. 18. FOR THAT the DRP erred in applying the decision of the jurisdictional tribunal in the case of Phillips India and the Delhi High Court in the case of Rio Tinto, when both these

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account was returned in the books of accounts. The assessing officer added 25% of the bogus purchases booked by the assessee but ignored the sales booked to the fictitious parties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on the ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account was returned in the books of accounts. The assessing officer added 25% of the bogus purchases booked by the assessee but ignored the sales booked to the fictitious parties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on the ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account was returned in the books of accounts. The assessing officer added 25% of the bogus purchases booked by the assessee but ignored the sales booked to the fictitious parties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on the ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account was returned in the books of accounts. The assessing officer added 25% of the bogus purchases booked by the assessee but ignored the sales booked to the fictitious parties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on the ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then

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

price, as such, profit on this account\nwas returned in the books of accounts. The assessing officer added 25% of the bogus\npurchases booked by the assessee but ignored the sales booked to the fictitious\nparties. Hon'ble Tribunal deleted the addition made on account of bogus purchases on\nthe ground that in case the bogus purchases are disallowed then