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171 results for “transfer pricing”+ Section 69Aclear

Sorted by relevance

Delhi230Mumbai171Jaipur91Bangalore64Cochin61Hyderabad51Chandigarh42Ahmedabad37Rajkot30Chennai29Kolkata26Indore23Surat20Agra15Pune15Amritsar11Nagpur11Jodhpur4Lucknow4Karnataka3Visakhapatnam3Allahabad2Rajasthan1Cuttack1SC1Varanasi1Raipur1

Key Topics

Addition to Income96Section 14A74Section 69A67Section 69C67Disallowance50Section 13245Section 153A44Section 143(3)43Section 6837Survey u/s 133A

DEPUTY CIT-5(1)(1), MUMBAI, MUMBAI vs. M/S ESSAR SHIPPING LIMITED , MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 821/MUM/2022[2015-16]Status: DisposedITAT Mumbai14 Nov 2022AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri M Balaganesh, Am आयकरअपीलसं./ I.T.A. No. 821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2015-16) M/S Essar Shipping Dy. Cit-Circle – 5(3)(1), Limited R. No. 568, Aayakar बिधम/ Essar House, 11, K K Bhavan, M. K. Road, Vs. Marg, Mahalaxmi, Mumbai-400 020 Mumbai-400 034 स्थायीलेखासं./जीआइआरसं./ Pan No. Aacce3707D (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Prakash R. Mane, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Manoj Patwari/ Shri Rishav Patwari, Ld. Ars सुनवाईकीतारीख/ : 18.08.2022 Date Of Hearing घोषणाकीतारीख / : 14.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Impugned Order Dated 28.02.2022, Passed By Ld. Cit (Appeals)-56, Mumbai For The Quantum Of Assessment Passed U/S 143(3) R.W.S.

For Appellant: Shri Prakash R. ManeFor Respondent: Shri Manoj Patwari/ Shri
Section 115VSection 143(3)Section 28Section 43Section 92

Showing 1–20 of 171 · Page 1 of 9

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32
Section 14828
Undisclosed Income24
Section 92F

pricing adjustment of Rs. 1.46 crores made by the AO @ 2% which has been restricted to 0.25% by the Ld. CIT (A) in respect of negative lien provided to associated entity. 10. Assessee has given has given ‘No Lien Undertaking’ to lenders (ICICI Bank Ltd, Hong Kong Branch and Singapore Branch) of Essar Global Ltd., wherein it has undertaken that

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 871/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 890/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 888/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

MRS. SUPREET KAUR NAGI,MUMBAI vs. ACIT CC 20, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 5940/MUM/2019[2003-04]Status: DisposedITAT Mumbai31 May 2022AY 2003-04

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SUPREET KAUR NAGI,MUMBAI vs. ACIT CC 20, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 5941/MUM/2019[2004-05]Status: DisposedITAT Mumbai31 May 2022AY 2004-05

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SPUREET KAUR NAGI,MUMBAI vs. ACIT CC 20, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 6835/MUM/2019[2009-10]Status: DisposedITAT Mumbai31 May 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SPUREET KAUR NAGI,MUMBAI vs. ACIT CC-20, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 6458/MUM/2019[2008-09]Status: DisposedITAT Mumbai31 May 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SPUREET NAGI,MUMBAI vs. ACIT CC-20, , MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 5942/MUM/2019[2005-06]Status: DisposedITAT Mumbai31 May 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SPUREET NAGI,MUMBAI vs. ACIT CC-20,, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 5944/MUM/2019[2007-08]Status: DisposedITAT Mumbai31 May 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

MRS. SPUREET NAGI,MUMBAI vs. ACIT CC-20,, MUMBAI

In the result ground number 9 of the appeal is allowed

ITA 5943/MUM/2019[2006-07]Status: DisposedITAT Mumbai31 May 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Jayesh Dadia, ARFor Respondent: Shri Shekhar L. Gajbhiye, CIT DR
Section 143(3)Section 153ASection 37(1)Section 69A

price of the property matches. The page no. 21 is for purchase of the property and page no. 22 is for the sale of the property. Further, sale consideration offered by the assessee for long term capital gain of ₹28,79,928/- are offered for taxation which is exactly to the sum of ₹28,80,000/- mentioned at page

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, , MUMBAI

In the result, all the appeals filed by the Revenue are\ndismissed

ITA 889/MUM/2025[2013-14]Status: DisposedITAT Mumbai29 Sept 2025AY 2013-14
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

Transfer Pricing Officer (TPO) noted that the\nassessee had not charged any commission for extending such\nguarantees. He was of the opinion that the transaction was an\ninternational transaction that required benchmarking, and\naccordingly determined the arm's length commission at 1.5%.\nBased on such adjustment, additions were made to the\nassessee's income for the respective assessment years

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are\ndismissed

ITA 872/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Sept 2025AY 2017-18
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

Transfer Pricing Officer (TPO) noted that the\nassessee had not charged any commission for extending such\nguarantees. He was of the opinion that the transaction was an\ninternational transaction that required benchmarking, and\naccordingly determined the arm's length commission at 1.5%.\n\n4\nITA No. 871/Mum/2025 and others\nViraj Profiles Private Limited\n\nBased on such adjustment, additions were

ACIT,CENTRAL CIRCLE-2(3), MUMBAI, MUMBAI vs. TANISHQ BUILDERS, MUMBAI

In the result, the appeal filed by the assessee is allowed, and the appeal filed by the Revenue is dismissed

ITA 8105/MUM/2025[2024-2025]Status: DisposedITAT Mumbai20 Feb 2026AY 2024-2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 139Section 143(3)Section 147Section 69A

price, I decided to prepare these bogus charts/chits to demonstrate that the sale of flats are at Rs.27,500/- per sq ft. I confirm that except five flats sold through me as above, I am not involved in sale of any other flats. Various facts were repeatedly put and explained to the Authorized Officers but applying pressure tactics, they forced

TANISHQ BUILDERS,MUMBAI vs. THE ACIT CC 2(3), MUMBAI

In the result, the appeal filed by the assessee is allowed, and the appeal filed by the Revenue is dismissed

ITA 5952/MUM/2025[2024-25]Status: DisposedITAT Mumbai20 Feb 2026AY 2024-25

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 139Section 143(3)Section 147Section 69A

price, I decided to prepare these bogus charts/chits to demonstrate that the sale of flats are at Rs.27,500/- per sq ft. I confirm that except five flats sold through me as above, I am not involved in sale of any other flats. Various facts were repeatedly put and explained to the Authorized Officers but applying pressure tactics, they forced

BHISHMA AGRO FOOD PRODUCTS PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(2) MUMBAI, MUMBAI

In the result ITA number 2376/M/2023 filed by the learned AO for assessment year 2021 – 22 is dismissed

ITA 2067/MUM/2023[2015-16]Status: DisposedITAT Mumbai12 Apr 2024AY 2015-16

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Rajiv Khandelwal, CA
Section 132Section 143Section 153CSection 68Section 69C

69A of the Income Tax Act, 1961 amounting to ₹42,79,483/- made by the Assessing Officer, without considering the facts and circumstances of the case and settled position of law." 3. Brief facts of the case show that :- i. Assessee is a domestic company engaged in the business of manufacturing of coca, chocolates and super confectioneries. ii. Search under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), MUMBAI vs. M/S BHISMA AGRO FOOD PRODUCTS PVT LTD, MUMBAI

In the result ITA number 2376/M/2023 filed by the learned AO for assessment year 2021 – 22 is dismissed

ITA 2373/MUM/2023[2018-2019]Status: DisposedITAT Mumbai12 Apr 2024AY 2018-2019

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Rajiv Khandelwal, CA
Section 132Section 143Section 153CSection 68Section 69C

69A of the Income Tax Act, 1961 amounting to ₹42,79,483/- made by the Assessing Officer, without considering the facts and circumstances of the case and settled position of law." 3. Brief facts of the case show that :- i. Assessee is a domestic company engaged in the business of manufacturing of coca, chocolates and super confectioneries. ii. Search under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), MUMBAI vs. M/S BHISMA AGRO FOOD PRODUCTS PVT LTD, DELHI

In the result ITA number 2376/M/2023 filed by the learned AO for assessment year 2021 – 22 is dismissed

ITA 2377/MUM/2023[2014-2015]Status: DisposedITAT Mumbai12 Apr 2024AY 2014-2015

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Rajiv Khandelwal, CA
Section 132Section 143Section 153CSection 68Section 69C

69A of the Income Tax Act, 1961 amounting to ₹42,79,483/- made by the Assessing Officer, without considering the facts and circumstances of the case and settled position of law." 3. Brief facts of the case show that :- i. Assessee is a domestic company engaged in the business of manufacturing of coca, chocolates and super confectioneries. ii. Search under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), MUMBAI vs. BHISMA AGRO FOOD PRODUCTS PVT LTD, MUMBAI

In the result ITA number 2376/M/2023 filed by the learned AO for assessment year 2021 – 22 is dismissed

ITA 2371/MUM/2023[2015-2016]Status: DisposedITAT Mumbai12 Apr 2024AY 2015-2016

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Rajiv Khandelwal, CA
Section 132Section 143Section 153CSection 68Section 69C

69A of the Income Tax Act, 1961 amounting to ₹42,79,483/- made by the Assessing Officer, without considering the facts and circumstances of the case and settled position of law." 3. Brief facts of the case show that :- i. Assessee is a domestic company engaged in the business of manufacturing of coca, chocolates and super confectioneries. ii. Search under

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), MUMBAI vs. M/S BHISMA AGRO FOOD PRODUCTS PVT LTD, DELHI

In the result ITA number 2376/M/2023 filed by the learned AO for assessment year 2021 – 22 is dismissed

ITA 2376/MUM/2023[2021-22]Status: DisposedITAT Mumbai12 Apr 2024AY 2021-22

Bench: Shri Aby T Varkey, Jm & Shri Prashant Maharishi, Am

For Appellant: Shri Rajiv Khandelwal, CA
Section 132Section 143Section 153CSection 68Section 69C

69A of the Income Tax Act, 1961 amounting to ₹42,79,483/- made by the Assessing Officer, without considering the facts and circumstances of the case and settled position of law." 3. Brief facts of the case show that :- i. Assessee is a domestic company engaged in the business of manufacturing of coca, chocolates and super confectioneries. ii. Search under