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94 results for “transfer pricing”

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Key Topics

Section 11135Addition to Income78Section 2(15)61Section 12A56Section 26347Section 143(3)39Exemption36Disallowance30Section 14729

MIRZA INTERNATIONAL LIMITED,KANPUR vs. DCIT CIRCLE 2(1)(1), KANPUR

The appeals of the assessee stand partly allowed

ITA 35/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-2018

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri Akshay Gupta, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 143(3)Section 40A(7)Section 80Section 92Section 92C

Transfer Pricing ITA Nos. 35 & 158 /LKW/2022 Page 16 of 25 study it is upto the Transfer Pricing Officer to record

SUPERHOUSE LIMITED,KANPUR vs. CIT, INTERNATIONAL TAXATION-3, DELHI, DELHI

Showing 1–20 of 94 · Page 1 of 5

Natural Justice25
Section 14822
Section 6821

In the result, both appeals of the assessee are allowed

ITA 356/LKW/2024[2014-15]Status: DisposedITAT Lucknow25 Feb 2026AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos. 356 & 357/Lkw/2024 A.Ys. 2014-15 & A.Ys. 2015-16 Superhouse Limited, 150 Feet Vs. The Commissioner Of Income Tax Road, Jajmau, Kanpur-208010 International Taxation-3, Delhi Pan: Aabcs9328K (Appellant) (Respondent) Assessee By: Sh. G.C. Srivastava, Adv & Sh. Kalrav Mehrotra, Adv Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 03.12.2025 Date Of Pronouncement: 25.02.2026 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed By The Assessee Against The Orders Of The Cit, (International Taxation)-3, Delhi Passed Under Section 263 Of The Act For The A.Ys. 2014-15 & 2015-16, Both Dated 29.03.2024, Wherein The Ld. Cit Has Set Aside The Earlier Orders Of The Assessing Officer For Making Of Fresh Orders In Accordance With The Directions Issued By Her. The Grounds Of Appeal Are As Under:- “1. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming Jurisdiction Under Section 263 Of The Act & In Doing So, Has Sought To Substitute His Opinion With The Order Under Section 201(1)/201(1A) Passed After Undertaking Extensive & Detailed Consideration Of The Issue By The Ito (Tds). 2. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming The Jurisdiction Under Section 263 Of The Act Without Appreciating That The Order Under Section 201(1)/201(1A) Passed By The Ito (Tds) Was Unerring & In Consonance With The Settled Principles Of Law. 3. Because, On The Facts & Circumstances Of The Case & In Law, The Impugned Order While Premised On An Illegal Assumption Of Jurisdiction, Further Suffers From Non-Application Of Mind Since The Submissions Of The Assessee Have Not Been Considered [As Illustrated Infra]. A.Ys. 2014-15 & 2015-16

For Appellant: Sh. G.C. Srivastava, Adv & Sh. KalravFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 201(1)Section 263Section 90

transfer pricing orders passed by the Transfer Pricing Officers and the subsequent appeal orders in respect of those transfer pricing

ASTT. COMMISSIONER OF INCOME TAX, LUCKNOW vs. M/S PRAG INDUSTRIES (INDIA) PVT. LTD., LUCKNOW

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

ITA 660/LKW/2016[2013-14]Status: DisposedITAT Lucknow11 Dec 2024AY 2013-14

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

Section 40A(2)

Price) under Transfer Pricing and has no relevance to present case in which Transfer Pricing issue is not involved. Transfer

VINAI SHUKLA,LUCKNOW vs. ACIT-1, LUCKNOW NEW, LUCKNOW

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

ITA 624/LKW/2024[2017-18]Status: DisposedITAT Lucknow12 Sept 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.624/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Vinai Shukla V. Acit-1, Lucknow New 2/280, Vikas Khand Gomti Lucknow Nagar, Lucknow-226010. Pratyaksh Kar Bhawan, Lucknow-226001. Pan:Asnps3558C अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Ms Shweta Mittal, Ca प्रत्यर्थी कक और से /Respondent By: Shri Prajesh Srivastava, Sr. Dr सुनवाई कक तारीख / Date Of Hearing: 21 08 2025 घोर्णा कक तारीख/ Date Of 12 09 2025 Pronouncement: आदेश / O R D E R

For Appellant: Ms Shweta Mittal, CAFor Respondent: Shri Prajesh Srivastava, Sr. DR
Section 143(2)Section 153Section 50C

Transfer Pricing Officer, within two months from the end of the month in which such order of the Transfer Pricing

PRECIOUS BJUILDTECH PRIVATE LIMITED,BAREILLY vs. PCIT, , BAREILLY

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

ITA 66/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Sept 2025AY 2017-2018

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.66/Lkw/2022 ननिाारण वर्ा/ Assessment Year: 2017-18 Precious Buildtech Pvt Ltd V. Pcit Harmony Apartment, Adiacent Income Tax Department, To Bedi International School, Bareilly-243001. Dental College Road, Pilibhit Bypass Road, Bareilly-243001. Pan:Aagcp1255R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Rakesh Garg, Adv प्रत्यर्थी कक और से /Respondent By: Shri Mazhar Akram, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 24 07 2025 घोर्णा कक तारीख/ Date Of 30 09 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Mazhar Akram, CIT(DR)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial

SHIMLA PROPERTIES,LUCKNOW vs. PR. COMMISSIONER OF INCOME TAX, LUCKNOW

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

ITA 113/LKW/2022[2012-13]Status: DisposedITAT Lucknow01 Sept 2022AY 2012-13

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 Shimla Properties V. The Pcit 30C, Datiya House Lucknow Khursheed Bagh Lucknow Tan/Pan:Ablfs9732M (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Neeraj Kumar, Cit (Dr) Date Of Hearing: 16 08 2022 Date Of Pronouncement: 01 09 2022 O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Neeraj Kumar, CIT (DR)
Section 143(1)Section 147Section 263

Transfer Pricing Officer, as the case may be, is erroneous in so far as it is prejudicial to the interests

M/S RAHMAN INDUSTRIES LTD,KANPUR vs. ASSTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

In the result, the appeal of the assessee stands allowed for

ITA 415/LKW/2018[2012-13]Status: DisposedITAT Lucknow22 Feb 2019AY 2012-13

Bench: Shri A.D Jain & Shri T.S. Kapoor

Section 14ASection 195Section 36(1)(va)Section 43B

transfer pricing adjustments on the basis of the report of the TPO, the addition is contrary to the provisions of law, misconceived

M/S RAHMAN INDUSTRIES LTD,KANPUR vs. ASSTT. COMMISSIONER OF INCOME TAX-VI, KANPUR

In the result, the appeal of the assessee stands allowed for

ITA 416/LKW/2018[2013-14]Status: DisposedITAT Lucknow22 Feb 2019AY 2013-14

Bench: Shri A.D Jain & Shri T.S. Kapoor

Section 14ASection 195Section 36(1)(va)Section 43B

transfer pricing adjustments on the basis of the report of the TPO, the addition is contrary to the provisions of law, misconceived

ALLIANCE NIRMAAN LIMITED,BAREILLY vs. PCIT, BAREILLY

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18
Section 143(3)Section 263

transferred to the buyer the property in the goods for a price or all\nsignificant risks and rewards of ownership

M/S. SAHARA CITY HOMES,BAREILLY vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

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

ITA 24/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 M/S Sahara City Homes – Bareilly V. Ito-3(4) 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2472C (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Amritsar V. Ito-3(4) 2, Sahara India Centre Lucknow Tan/Pan:Abzfs4654E (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Kanpur(I) V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2468Q (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Guwahati V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2462E (Appellant) (Respondent)

transfer of WIP and related land and development rights; that the WIP was an existing asset, for which, the consideration had been fixed at Rs.46,84,19,482/-; that the land and development rights were to be acquired by the transferor within a period of one year and the price

M/S. SAHARA CITY HOMES,RAJKOT vs. INCOME TAX OFFICER- 34), RANGE-3, LUCKNOW

ITA 38/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,AMRITSAR vs. INCOME TAX OFFICER- 3(4), LUCKNOW

ITA 25/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,VADODARA vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 33/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,ANAND vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 39/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,AMBALA vs. INCOME TAX OFFICER -3(4), RANGE-3, LUCKNOW

ITA 34/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,KARNAL vs. INCOME TAX OFFICER -3(4), RANGE-3, LUCKNOW

ITA 36/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,MUZAFFAR NAGAR vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

ITA 35/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,DEVAS vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 28/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,JAMNAGAR vs. INCOME TAX OFFICER -3(4), LUCKNOW

ITA 37/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance

M/S. SAHARA CITY HOMES,KANPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE- 3, LUCKNOW

ITA 26/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13
For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt
Section 69C

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance