BharatTax.net
SearchITATHigh CourtsSupreme CourtAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

16 results for “transfer pricing”+ Section 36(1)(via)clear

Sorted by relevance

Mumbai224Delhi168Chandigarh65Bangalore62Jaipur60Chennai59Ahmedabad43Hyderabad34Kolkata19Pune16Guwahati16Indore12Nagpur11Cuttack8Amritsar4Rajkot3Surat3Cochin2Visakhapatnam1Lucknow1Jodhpur1

Key Topics

Section 143(3)21Section 8020Section 26312Section 115J12Section 5710Section 143(2)9Deduction8Section 1326Section 1476Addition to Income

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

ITA 1994/PUN/2024[2020-21]Status: DisposedITAT Pune06 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80

Transfer Pricing Officer under sub- Section (3) of Section 92CA and even under Section 144C(8). The DRP may confirm, reduce or enhance the variations proposed in the draft order and wherefore the word eligible assessee in Clause (1) and (15) and the proposed draft order referred to under Clause 144c(1) and (8) will have to be given full

6
Disallowance5
Transfer Pricing3

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHPAUR vs. RBL BANK LTD, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

ITA 657/PUN/2024[2014-15]Status: DisposedITAT Pune30 Sept 2024AY 2014-15

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

Section 139(1)Section 143(2)Section 250Section 271Section 271(1)(c)

transfer of humanskill is a revenue, though the benefit may be of enduring in nature. Hence, the said expenditure has to betreated as revenue expenditure. The order passed by the Assessing Officer to disallow the expenditure asrevenue expenditure is erroneous in law. 38. In the context of business take over by Banks, the Reserve Bank of India has specifically provided

DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. BANK OF MAHARASHTRA, PUNE

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 428/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

via) that the provision should relate to rural advances.\n2. 3. The learned CIT(A) failed to appreciate the fact the entire provision made has to be considered and not the provision relating to rural advances only be considered.\n2. 4. The learned CIT(A) failed to appreciate the fact that the Hon'ble Supreme Court in the case

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

ITA 692/PUN/2022[2018-19]Status: DisposedITAT Pune02 Nov 2023AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

Section 143(3)Section 144Section 144(11)Section 144(7)Section 144BSection 144C(6)(C)

via video conference and without providing an opportunity to the Appellant to file a written submission in response to the Show-cause notice. Dispute Resolution Panel (‘Ld. DRP’) erred in upholding the same by contending that there was no denial of opportunity to the appellant.  Further, the Ld. DRP erred in not providing an opportunity to the appellant to provide

BANK OF MAHARASHTRA ,PUNE vs. ASST COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 259/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

For Appellant: Shri S Ananthan & Smt. Abarna CAFor Respondent: Shri Amol Khairnar CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

via) that the provision should relate to rural advances. 2.3. The learned CIT(A) failed to appreciate the fact the entire provision made has to be considered and not the provision relating to rural advances only be considered. 2.4. The learned CIT(A) failed to appreciate the fact that the Hon'ble Supreme Court in the case of Catholic Syrian

DANA ANAND INDIA PRIVATE LIMITED,PUNE vs. DCIT, AKURDI,PUNE

ITA 1571/PUN/2024[2020-21]Status: DisposedITAT Pune04 Apr 2025AY 2020-21
Section 143(1)(a)Section 143(3)Section 154Section 37Section 37(1)Section 41Section 41(1)Section 80ASection 80G

VIA has been claimed by the appellant in respect\nof the amount donated voluntarily to the donee out of its own volition and\nbenefit thereof has been claimed at the stage of computation of its total\nincome as per the provisions of Section 80A of the Act.\nII.\nDisallowance under section 41(1) of the Act\n3.\nThe learned

ASHISH NIRANJAN SHAH,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX -4,, PUNE

In the result, appeal of the assessee is dismissed

ITA 697/PUN/2019[2014-15]Status: DisposedITAT Pune13 Oct 2023AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.697/Pun/2019 िनधा"रण वष" / Assessment Year : 2014-15 Ashish Niranjan Shah, The Pr.Cit-4, Pune. 39, Mantri Court, Dr.Ambedkar V Road, Next To Rto, Sangam, S Pune – 411001. Pan: Aidps 7682 K Appellant/ Assessee Respondent /Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Keyur Patel, Irs – Cit-Dr Date Of Hearing 28/07/2023 Date Of Pronouncement 13/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Pr.Commissioner Of Income Tax-4, Pune Dated26.03.2019 Under Section 263 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Learned Pr. Cit- 4, Pune Erred In Law & On Facts In Treating The Assessment Order U/S 143(3) Being Erroneous & Thereby Prejudicial To The Revenue U/S 263 Without Appreciating That, The Learned Ao Has Allowed Appellant'S Claim Of Business Loss Amounting To Rs.10,20,14,068/- Incurred On Account Of Default In Payment By Nsel, With Due Application Of Mind & Verification. The Learned Pr. Cit Erred In Holding That, Ao Has Not Carried Out Any Enquiry With Respect To Business Loss Claimed By The Appellant & Not Applied His Ashish Niranjan Shah [A]

Section 143(3)Section 263Section 43(5)

VIA viz. Purchase document, Sale deeds or any other documentary evidences. 9. Please furnish the Power of Attorney.” In the other notice u/s 142, there is no specific question. 5.3 Thus, it can be seen that the AO had not asked any question regarding the Loss claimed by the assessee. The Assessee has shown the Loss as under

SHARADA ELECTORS PRIVATE LIMITED,PUNE vs. PCIT, PUNE-3, PUNE

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

ITA 1432/PUN/2025[2020-21]Status: DisposedITAT Pune22 Sept 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amit Bobde
Section 142(1)Section 143(1)Section 143(2)Section 14ASection 263

via show cause e-notice have now explained with proper justification. Accordingly, in the light of factual matrix no adverse inference may be drawn and thus the returned income of the assessee is accepted.” 3. Thereafter, ld. PCIT called for the assessment records and after going through the same assumed jurisdiction u/s.263 of the Act and issued assessee a show

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]
Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

transferred to Ld. CIT(E) jurisdiction. The Ld. CIT(E) vide notice dt. 24/03/2017 revived former cancellation proceedings and before culmination had granted reasonable opportunities to enable the assessee to rebut Revenue’s negative observations/findings. After analysis of facts with an elaborate discussion laid in para 4, the Ld. CIT(E) by the impugned order dt.28/03/2018 has finally withdrawn/cancelled

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 229/PUN/2025[2013-14]Status: DisposedITAT Pune23 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

Via SVP Circle, Goa Hotel, Lalgeri Cross & Shahabazarcross to Ring Road in Gulbarga City" Further, in the bill of Contract Receipt Bidar, Karnataka it is also clearly mentioned as: Name of Work "Work services for Resurfacing of Runway & Taxi Tracks, Renovating Rigid Dispersal and Associated works at 406 AFS Bidar" 7. He, therefore, was of the opinion that the assessee

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 231/PUN/2025[2015-16]Status: DisposedITAT Pune23 Oct 2025AY 2015-16

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

Via SVP Circle, Goa Hotel, Lalgeri Cross & Shahabazarcross to Ring Road in Gulbarga City" Further, in the bill of Contract Receipt Bidar, Karnataka it is also clearly mentioned as: Name of Work "Work services for Resurfacing of Runway & Taxi Tracks, Renovating Rigid Dispersal and Associated works at 406 AFS Bidar" 7. He, therefore, was of the opinion that the assessee

JAYANTI S KUNDHADIYA, ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), PUNE, PUNE vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LIMITED, MUMBAI

In the result, all the three appeals filed by the Revenue are allowed for statistical purposes

ITA 230/PUN/2025[2014-15]Status: DisposedITAT Pune23 Oct 2025AY 2014-15

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Rajiv KhandelwalFor Respondent: Shri Amit Bobde, CIT
Section 143(2)Section 80

Via SVP Circle, Goa Hotel, Lalgeri Cross & Shahabazarcross to Ring Road in Gulbarga City" Further, in the bill of Contract Receipt Bidar, Karnataka it is also clearly mentioned as: Name of Work "Work services for Resurfacing of Runway & Taxi Tracks, Renovating Rigid Dispersal and Associated works at 406 AFS Bidar" 7. He, therefore, was of the opinion that the assessee

SHAHU SHIKSHAN PRASARAK MANDAL, LATUR,LATUR vs. ACIT (EXMP.) CIRCLE, AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

ITA 951/PUN/2024[2020-21]Status: DisposedITAT Pune15 Jan 2025AY 2020-21
For Appellant: \nDepartment by
Section 10Section 12ASection 142(1)Section 143(3)Section 56Section 57

via) are required to\nobtain the approval of CCIT / PCIT. The trust is running schools which\nare mostly granted by Government in the year between 1990-2000.\nCertificates from School Education Department, Government of\nMaharashtra confirming the amount of grants distributed to schools\nrun by trust is enclosed herewith as Annexure \"E\".\n2) Perusal of the Pay sheets as claimed

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

ITA 1565/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19
For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(3)Section 147Section 148Section 153A

via Account Payee Cheques, held in a DEMAT Account for over 12\nmonths, and sold through a recognized stockexchange after payment of security\ntransaction tax. On further appeal, Tribunal upheld CIT(A)'s decision, criticizing the\nassessing officer's reliance on statements from 'entry operators' to support additions\nunder sections 68 and 69 as those statements were recorded in unrelated

ASSISTANT COMMISSIONER OF INCOME TAX, JALGAON vs. SIDHARTH RATANLAL BAFNA, JALGAON

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14
Section 132Section 143(3)Section 147Section 148Section 153A

via Account Payee Cheques, held in a DEMAT Account for over 12\nmonths, and sold through a recognized stockexchange after payment of security\ntransaction tax. On further appeal, Tribunal upheld CIT(A)'s decision, criticizing the\nassessing officer's reliance on statements from 'entry operators' to support additions\nunder sections 68 and 69 as those statements were recorded in unrelated

DEPUTY COMMISSIONER OF INCOME TAX, JALGAON vs. TARADEVI RATANLAL BAFNA, JALGAON

ITA 497/PUN/2025[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14
Section 132Section 143(3)Section 147Section 148Section 153A

via Account Payee Cheques, held in a DEMAT Account for over 12\nmonths, and sold through a recognized stockexchange after payment of security\ntransaction tax. On further appeal, Tribunal upheld CIT(A)'s decision, criticizing the\nassessing officer's reliance on statements from 'entry operators' to support additions\nunder sections 68 and 69 as those statements were recorded in unrelated