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43 results for “transfer pricing”+ Section 69Bclear

Sorted by relevance

Delhi147Jaipur87Mumbai43Bangalore23Chandigarh22Cochin19Chennai15Agra14Ahmedabad13Amritsar11Indore6Pune5Surat5Raipur4Allahabad2Rajkot2Jodhpur2Hyderabad1Ranchi1SC1

Key Topics

Section 153A42Addition to Income37Section 69B30Section 143(3)26Section 6917Section 69A14Section 6813Section 14812Disallowance11Section 132

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 43 · Page 1 of 3

10
Search & Seizure7
Survey u/s 133A5
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

ABALABBA DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ITO-12(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2949/MUM/2023[2013-14]Status: DisposedITAT Mumbai12 Apr 2024AY 2013-14

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri M M Golvala, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. DR
Section 133(6)Section 2(24)Section 234BSection 57(2)Section 69Section 698Section 69B

69B without giving any finding as to how the said Sections were applicable to the facts of the Appellant's case. 4) Both the lower authorities erred in ignoring decisions of the High Courts led before them. 5) Both the lower authorities erred in ignoring the fact that under a Family Settlement, there is no transfer of property. 6) Having

SATGURU CORPORATE SERVICES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 11(1)(3), MUMBAI

In the result, the appeal of the Revenue

ITA 483/MUM/2018[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Dr. Kishor Dhule, CIT-DR
Section 69

price and the appellant offers no explanation about such excess, amount or the explanation offered by explanation about such excess, amount or the explanation offered by explanation about such excess, amount or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, Section him is not, in the opinion of the Assessing Officer, satisfactory, Section

INCOME TAX OFFICER 11(2)(1), MUMBAI vs. SATGURU CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue

ITA 878/MUM/2018[2012-13]Status: DisposedITAT Mumbai09 Oct 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Dr. Kishor Dhule, CIT-DR
Section 69

price and the appellant offers no explanation about such excess, amount or the explanation offered by explanation about such excess, amount or the explanation offered by explanation about such excess, amount or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, Section him is not, in the opinion of the Assessing Officer, satisfactory, Section

TATA MOTORS LTD,MUMBAI vs. DCIT LTU 2, MUMBAI

In the result, appeal of the assessee is allowed

ITA 3425/MUM/2019[2012-13]Status: DisposedITAT Mumbai05 Mar 2021AY 2012-13
Section 115BSection 143(3)Section 2(47)Section 263Section 71

Price (loss) Index Factor Rs. Rs. TML Holdings Pic Lid - Preference 1 shares 20,48,999 8,36,19,21,837 785/532 11,27,85,37,185 9,15,76,21,933 (2,12,09,15,252) TML Holdings Pte Lid - Preference 2 shares 5,00,000 2,43,18,62,500 785/582

ITO 1(2)(3), MUMBAI vs. MAHESH CONBUILD P.LTD, MUMBAI

The appeal stands dismissed

ITA 5808/MUM/2016[2012-13]Status: DisposedITAT Mumbai05 Oct 2018AY 2012-13

Bench: Shri Manoj Kumar Aggarwal, Am & Shri Ravish Sood, Jm

For Appellant: Hiro Rai, Ld. ARFor Respondent: Manoj Kumar Singh, Ld. Sr. DR
Section 131Section 143(3)Section 69B

prices and therefore, invoking the provisions of Section 69B, the differential amount of Rs.98.88 Lacs was added to the income of the assessee. 3. Aggrieved, the assessee contested the same with success before Ld. CIT(A) vide impugned order dated 22/03/2016 wherein the assessee, inter-alia, contended that merely because the stamp duty value was higher than agreed consideration

ITO 1(2)(1), MUMBAI vs. JAS PROPBUILD P.LTD, MUMBAI

The appeal stands dismissed

ITA 4382/MUM/2016[2012-13]Status: DisposedITAT Mumbai05 Oct 2018AY 2012-13

Bench: Shri Manoj Kumar Aggarwal, Am & Shri Ravish Sood, Jm

For Appellant: Hiro Rai, Ld. ARFor Respondent: Manoj Kumar Singh, Ld. Sr. DR
Section 131Section 143(3)Section 69B

prices and therefore, invoking the provisions of Section 69B, the differential amount of Rs.98.88 Lacs was added to the income of the assessee. 3. Aggrieved, the assessee contested the same with success before Ld. CIT(A) vide impugned order dated 22/03/2016 wherein the assessee, inter-alia, contended that merely because the stamp duty value was higher than agreed consideration

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

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

69B of the Act. The learned CIT(A) confirmed the action of the learned Assessing Officer. 57. Similarly, on the backside of the same paper there is a mentioned of fixed deposit amounting to ₹10,05,000/- and the learned Assessing Officer also made the addition of the same which was also confirmed by the learned CIT (A). ITA no.6835

DCIT 3(2)(2), MUMBAI vs. THE NEW INDIA ASSURANCE CO.LTD, MUMBAI

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

ITA 5013/MUM/2015[2010-11]Status: DisposedITAT Mumbai28 Mar 2018AY 2010-11

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2010-11

For Appellant: Shri Farrokh V. Irani, A.RFor Respondent: Shri Narendra Singh Janpan, D.R
Section 69B

transferred in his name for various reasons and thus this is the reason for the difference in number of shares as per the records maintained by the assessee which represents only a notional difference which would be resolved as and then the buyer takes delivery of the shares. The assessee also submitted that the said balance of Rs.27

THE NEW INDIA ASSURANCE COMPANY LTD,MUMBAI vs. DCIT (OSD) 1(2), MUMBAI

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

ITA 5090/MUM/2015[2010-11]Status: DisposedITAT Mumbai28 Mar 2018AY 2010-11

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2010-11

For Appellant: Shri Farrokh V. Irani, A.RFor Respondent: Shri Narendra Singh Janpan, D.R
Section 69B

transferred in his name for various reasons and thus this is the reason for the difference in number of shares as per the records maintained by the assessee which represents only a notional difference which would be resolved as and then the buyer takes delivery of the shares. The assessee also submitted that the said balance of Rs.27

M/S EVERFINE CONSTRUCTIONS PVT. LTD.,MUMBAI vs. DCIT CC-7(3), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3129/MUM/2019[2011-12]Status: DisposedITAT Mumbai16 Sept 2021AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Sanjeev Kashyap
Section 133ASection 143(3)Section 147Section 148Section 68

section 69B has been invoked by Assessing Officer or CIT(A) either and hence, whole addition is invalid on this count too. 12. On contrary, the Ld. DR for the revenue sought to rely on the order of the lower authorities. He strongly argued that the findings in the Due Diligence report of M/s. Gulmohar Towers Pvt. Ltd. itself shows

SATYAPAL JAIN,MUMBAI vs. DCIT, CETRAL CIRCLE - 39, MUMBAI

In the result, both the appeal filed by the assessee are partly allowed

ITA 2718/MUM/2013[2007-08]Status: DisposedITAT Mumbai26 Nov 2015AY 2007-08

Bench: Shri Amit Shukla & Shri Ashwani Taneja

For Respondent: Shri Rajesh Rajan Prasad
Section 132Section 132(1)Section 143(3)Section 153ASection 23(1)(a)Section 69B

price in these loose sheets just to extract monies from their higher authorities in the guise of On-Money to be paid to the vendors. May be because of his possibility no documents were found to show that the money actually changed hands. 25. A perusal of the balance sheet of the assessee show that the authorized, issued and subscribed

SATYAPAL JAIN,MUMBAI vs. DCIT, CETRAL CIRCLE - 39, MUMBAI

In the result, both the appeal filed by the assessee are partly allowed

ITA 2719/MUM/2013[2006-07]Status: DisposedITAT Mumbai26 Nov 2015AY 2006-07

Bench: Shri Amit Shukla & Shri Ashwani Taneja

For Respondent: Shri Rajesh Rajan Prasad
Section 132Section 132(1)Section 143(3)Section 153ASection 23(1)(a)Section 69B

price in these loose sheets just to extract monies from their higher authorities in the guise of On-Money to be paid to the vendors. May be because of his possibility no documents were found to show that the money actually changed hands. 25. A perusal of the balance sheet of the assessee show that the authorized, issued and subscribed

WELSPUN CORP LTD,MUMBAI vs. DCIT CEN CIR 22, MUMBAI

In the result, the appeals filed by the revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3890/MUM/2016[2008-09]Status: DisposedITAT Mumbai03 Apr 2023AY 2008-09

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadale

Section 143(3)Section 14ASection 32(1)(iia)

price including duties and taxes other than those duties and taxes subsequently recoverable by enterprise from the taxing authorities. Thus, it was submitted in alternative ITA.No,3890&4364/5063&5483/5165&5043/5166&5044/Mum/2016 M/s. Welspun Corp Ltd, Mumbai. that even if the said incentives are treated as capital receipt by tribunal, the taxes recoverable from Government are not part of the cost