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7 results for “transfer pricing”+ Section 56(2)(viia)clear

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Key Topics

Section 54F7Addition to Income7Disallowance6Depreciation5Set Off of Losses4Section 2503Section 143(3)3Section 143(2)3Deduction3

M/S. CLASSIC CITI INVESTMENTS PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD-1(2), PUNE

In the result, the appeal for the A

ITA 435/PUN/2023[2016-17]Status: HeardITAT Pune21 Sept 2023AY 2016-17

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 250

transfer of 34000 Equity shares at value of Rs.11,764.70 per share. The assessee submitted valuation report in respect of Equity shares to Diana having the fair market of shares at Rs.11,680.00 per share under Discounted Cash Flow (DCF) method. The AO held that the shares acquired by the assessee from ABIL were undervalued at Rs.11,764.70 per share

M/S. CLASSIC CITI INVESTMENTS PRIVATE LIMITED,PUNE vs. THE INCOME TAX OFFICER, WARD-1(2), PUNE

In the result, the appeal for the A

ITA 436/PUN/2023[2017-18]Status: HeardITAT Pune21 Sept 2023AY 2017-18

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 2712
Section 250

transfer of 34000 Equity shares at value of Rs.11,764.70 per share. The assessee submitted valuation report in respect of Equity shares to Diana having the fair market of shares at Rs.11,680.00 per share under Discounted Cash Flow (DCF) method. The AO held that the shares acquired by the assessee from ABIL were undervalued at Rs.11,764.70 per share

RAJENDRA L.AGARWAL,,PUNE vs. INCOME-TAX OFFICER, (INTERNATIONAL TAXATION -I),, PUNE

ITA 2330/PUN/2017[2012-13]Status: DisposedITAT Pune31 Aug 2018AY 2012-13

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita No. 2330/Pun/2017 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Year : 2012-13 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Sunil PathakFor Respondent: Shri Rajeev Kumar &
Section 54F

section 56(2)(viia) in the assessee's case does not arise. It may be applicable in the case of Tapti. Hence, no purpose would be served by setting aside the asst. of the assessee. 2.5] Accordingly, the assessee submits that his case is totally genuine and the capital loss on sale of Shivalik shares should be allowed

JANATA SAHAKARI BANK LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

In the result, the appeal filed by the Revenue in ITA

ITA 2641/PUN/2017[2014-15]Status: DisposedITAT Pune10 May 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

viia) of the Act. Thus, this ground of appeal no.3 filed by the assessee stands dismissed. 16. Ground of appeal no.4 challenges the disallowance of bad debts amounting to Rs.53,23,92,280/- u/s 36(1)(vii). The Assessing Officer had disallowed the claim of Rs.53,23,92,280/- u/s 36(1)(vii) solely on the ground that the similar

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE vs. M/S. JANATA SAHAKARI BANK LTD,, PUNE

In the result, the appeal filed by the Revenue in ITA

ITA 2428/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

viia) of the Act. Thus, this ground of appeal no.3 filed by the assessee stands dismissed. 16. Ground of appeal no.4 challenges the disallowance of bad debts amounting to Rs.53,23,92,280/- u/s 36(1)(vii). The Assessing Officer had disallowed the claim of Rs.53,23,92,280/- u/s 36(1)(vii) solely on the ground that the similar

JANATA SAHAKARI BANK LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 6,, PUNE

In the result, the appeal filed by the Revenue in ITA

ITA 2400/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

viia) of the Act. Thus, this ground of appeal no.3 filed by the assessee stands dismissed. 16. Ground of appeal no.4 challenges the disallowance of bad debts amounting to Rs.53,23,92,280/- u/s 36(1)(vii). The Assessing Officer had disallowed the claim of Rs.53,23,92,280/- u/s 36(1)(vii) solely on the ground that the similar

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