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22 results for “transfer pricing”+ Section 69Dclear

Sorted by relevance

Jaipur35Delhi23Mumbai22Rajkot18Bangalore11Ahmedabad3Indore2Chennai1Nagpur1Pune1Allahabad1Surat1

Key Topics

Section 13229Addition to Income19Section 6812Section 1487Section 2637Section 115B7Section 143(3)6Section 115J4Section 14A3Disallowance2Unexplained Cash Credit2Cash Deposit2

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 92Section 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

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

DCIT ,CC- 8(4), MUMBAI vs. ASHOK R. RUIA (HUF), MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 6309/MUM/2019[2008-09]Status: DisposedITAT Mumbai28 Feb 2022AY 2008-09

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

For Appellant: Shri Vijay MehtaFor Respondent: Shri Shailja Rai
Section 132

transfer of any capital asset from the assessee to MAPL. That is the normal conclusion available on reading the chronology of events in the present case. In order to make a case of capital gains tax, the Assessing Officer is cutting the chain of events into two parts; one part upto 31-3-1999 and the other part after

MEENA HASMUKH SAVLA,MATUNGA MUMBAI vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE

In the result the appeal filed by the assessee is\nallowed

ITA 2910/MUM/2024[2016-17]Status: DisposedITAT Mumbai18 Feb 2025AY 2016-17
Section 10Section 10(38)Section 143Section 143(1)Section 143(2)Section 147Section 148Section 151Section 250Section 68

69D though he has stated to apply tax rate as\nper section 115BBE.\n\n8. 6. 4. If the inference is drawn that ld. AO has made a\ndisallowance of claim of exemption by the assessee u/s 10(38),\nthen, first and foremost, his statement of applying the rate of\n60% under section 115BBE does not hold good. Further

POOJA MARKETING,MUMBAI vs. PR. CIT- 31 , MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2596/MUM/2019[2014-15]Status: DisposedITAT Mumbai24 May 2021AY 2014-15

Bench: Us, The Core Issues To Be Decided Are As Under:-

Section 115BSection 263Section 58(4)

69D of the Act. In a subsequent Circular No. 11/2019 dated 19.6.2019, the CBDT further provided a clarification that an assessee is entitled to claim set-off of loss against income determined u/s. 115BBE of the Act till the Asst Year 2016-17. (xiv) The ld AR further submitted that Section 112 of the Act which was inserted

M/S. TATA INDUSTRIES LTD,MUMBAI vs. THE ITO 2(3)(3), MUMBAI

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

ITA 4894/MUM/2008[2004-2005]Status: DisposedITAT Mumbai20 Jul 2016AY 2004-2005

Bench: Shri G. S. Pannu, Accoutant Member & Shri Sanjay Gargtata Industries Ltd., Vs. The Income Tax Officer, Ward- Bombay House,24,Homi 2 (3) (3), Room No.555, Mody Street, Fort, Mumbai Aayakar Bhavan, Maharshi 400 001 Karve Road, Mumbai 400 020 Pan: Aaact 4058 L Appellant .. Respondent Appellant By Shri Dinesh Vyas, Ar Respondent By Shri Alok Johri, Dr Date Of Hearing 22-06-2016 Date Of Pronouncement 20-07-2016

Section 10ASection 115JSection 14ASection 36

69D of the Act are deemed income where entire sum is treated as income without following /applying matching principle (ix) Sec. 14A though included in the Chapter IV of the Act i.e computation of total income but it is having heading as “expenditure incurred in relation to income not includable in total income”. It is therefore to understand the heading

BHANDARI GOLD AND JEWELLERS PRIVATE LIMITED,MUMBAI vs. CIT (APPEAL), NFAC - DELHI

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1619/MUM/2022[2017-2018]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-2018

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 6(1)(2) V. M/S. Bandari Gold & Jewellers Pvt. Ltd., 407, Bussaudyog Bhavan Room No. 538B, 5Th Floor Tokersi, Jivraj Road, Sewree Aayakar Bhavan, M.K. Road Mumbai - 400015 Mumbai - 400020 Pan: Aadcb1291J (Appellant) (Respondent)

Section 143(3)Section 68

Section 115BBE are reproduced hereunder: 115BBE. (1) Where the total income ofan assessee,- (a) includes any income referred to in section 68, section 69, section 69A,section 69B, section 69C or section 69D and reflected in the return of income furnished under section 139; or (b) determined by the Assessing Officer includes any income referred to in section 68, section

CY. CIT 6(1) (2) , MUMBAI vs. M/S. BHANDARI GOLD & JEWELLERS PVT. LTD, MUMBAI

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1564/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-18

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 6(1)(2) V. M/S. Bandari Gold & Jewellers Pvt. Ltd., 407, Bussaudyog Bhavan Room No. 538B, 5Th Floor Tokersi, Jivraj Road, Sewree Aayakar Bhavan, M.K. Road Mumbai - 400015 Mumbai - 400020 Pan: Aadcb1291J (Appellant) (Respondent)

Section 143(3)Section 68

Section 115BBE are reproduced hereunder: 115BBE. (1) Where the total income ofan assessee,- (a) includes any income referred to in section 68, section 69, section 69A,section 69B, section 69C or section 69D and reflected in the return of income furnished under section 139; or (b) determined by the Assessing Officer includes any income referred to in section 68, section

LAYER EXPORTS P. LTD,MUMBAI vs. ACIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1907/MUM/2011[2005-06]Status: DisposedITAT Mumbai31 Oct 2016AY 2005-06

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

ACIT CEN CIR 24 & 26, MUMBAI vs. LAYER EXPORTS P. LTD, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 3019/MUM/2011[2004-05]Status: DisposedITAT Mumbai31 Oct 2016AY 2004-05

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P.LTD,MUMBAI vs. ACIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1929/MUM/2011[2007-08]Status: DisposedITAT Mumbai31 Oct 2016AY 2007-08

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

ACIT CEN CIR 21, MUMBAI vs. LAYER EXPORTS P.LTD, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 5613/MUM/2013[2010-11]Status: DisposedITAT Mumbai31 Oct 2016AY 2010-11

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P. LTD,MUMBAI vs. ACIT CEN CIR 21, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 3378/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Oct 2016AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

ACIT CEN CIR 21, MUMBAI vs. LAYER EXPORTS P.LTD, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1097/MUM/2013[2009-10]Status: DisposedITAT Mumbai31 Oct 2016AY 2009-10

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P.LTD,MUMBAI vs. ACIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1928/MUM/2011[2006-07]Status: DisposedITAT Mumbai31 Oct 2016AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P. LTD,MUMBAI vs. ASST CIT CEN CIR 21, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1842/MUM/2013[2008-09]Status: DisposedITAT Mumbai31 Oct 2016AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P.LTD,MUMBAI vs. ACIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1930/MUM/2011[2008-09]Status: DisposedITAT Mumbai31 Oct 2016AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

ACIT CEN CIR 24 & 26, MUMBAI vs. LAYER EXPORTS P. LTD, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 3021/MUM/2011[2008-09]Status: DisposedITAT Mumbai31 Oct 2016AY 2008-09

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

LAYER EXPORTS P.LTD,MUMBAI vs. ACIT CEN CIR 24 & 26, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 1927/MUM/2011[2004-05]Status: DisposedITAT Mumbai31 Oct 2016AY 2004-05

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

ACIT CEN CIR 24 & 26, MUMBAI vs. LAYER EXPORTS P. LTD, MUMBAI

In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue

ITA 2985/MUM/2011[2006-07]Status: DisposedITAT Mumbai31 Oct 2016AY 2006-07

Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am

Section 132

price was agreed at Rs. 2,37,52,2001- @ Rs. 12,6471- per sq. ft. (built up area). It was also agreed that parking space shall be provided at the time of possession. I further state that agreement for the said flat was executed on 10.10.2008 for total consideration at Rs. 2,37,52,2001-. Details of payments have been

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