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15 results for “transfer pricing”+ Section 153Cclear

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Key Topics

Section 25016Section 143(3)15Section 14814Addition to Income13Section 14712Survey u/s 133A6Section 133A4

JAMNADAS PURSHOTAM PATEL,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTER-1, RAJKOT

ITA 60/RJT/2025[2017-18]Status: DisposedITAT Rajkot22 Dec 2025AY 2017-18
Section 250

transfer of title and possession of property)\ninstead of year of receipts without appreciating the facts, evidences found and seized\nduring the course of search and circumstances of the peculiar case.\n4. In the facts and on the circumstances of the case and in law the ld. CIT(A) ought to\nhave upheld the order

KIRAN HARUBHAI DANGAR,JUNAGADH vs. ASSESSING OFFICER, RAJKOT

ITA 368/RJT/2023[2012-13]Status: DisposedITAT Rajkot10 Apr 2026AY 2012-13

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 132
Section 142(1)
Section 143(2)
Section 143(3)
Section 148
Section 153B
Section 153C
Section 250
Section 69

153C r.w.s. 153A and section 153B of the Act. (ii). The order of assessment passed u/s 143(3) r.w.s. 147 of the Act and the order u/s 250 of the Act are bad in law as they are passed without Document Identification Number (DIN) mentioning therein and hence they are to be treated as invalid in view of CBDT Circular

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 559/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 787/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

ITA 765/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 786/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 563/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 560/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 564/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

price with customer inclusive of all other add-on services provided by him) in various impounded documents/data as well as averments made by sales employee in his statement, estimation of unaccounted receipts at Rs. 30.22 crores as well as total receipts at Rs. 118.31 crores from entire project, i.e., 509 flats is strongly objected. 15. It is also submitted that

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

ITA 555/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

ITA 556/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE vs. MARUTI ENTERPRISE, RAJKOT

ITA 228/RJT/2023[2019-20]Status: DisposedITAT Rajkot22 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. It(Ss)A No Assessment Assessee Name Respondent Name No. Year 1. 12/Rjt/2024 2014-15 Deputy Commissioner Shri Chetan Dhirajlal Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Pan.:Afkpr4637P 2. 13/Rjt/2024 2014-15 Deputy Commissioner Shri Nikhilbhai Jamnadas Of Income-Tax, Central Patel Circle-1, Rajkot, P-1, Decora Highland, “Amruta Estate” 2Nd Avadh Main Road, Opp. Floor, M.G. Road, Classic Party Plot Rajkot- Rajkot-360 001 360 005 Pan No.: Agipp 1294 K 3. 17/Rjt/2024 2013-14 Deputy Commissioner Shri Dhirajlal Ravji Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Panno.:Abopr5408A 19 & 2017-18 & Deputy Commissioner Shri Rohitkumar Maganlal 4. 20/Rjt/2024 2018-19 Of Income-Tax, Central Sanepara Circle-1, Rajkot, Kangshiyani Road, Opp. “Amruta Estate” 2Nd Sundaram Vidhyalaya, Floor, M.G. Road, Dholra Chokdi, Kothariya, Rajkot-360 001 Rajkot-360 004 Panno.:Aaopp4848H 5. 59-60/Rjt/2023 2017-18 & Deputy Commissioner M/S Maruti Enterprise 2018-19 Of Income-Tax, Central Decora West Hills, Near Classic Party Plot, Opp. Circle-1, Rajkot, Kalawa Road, Rajkot-360 “Amruta Estate” 2Nd 005 Floor, M.G. Road, Rajkot-360 001 Panno.:Abdfm3140K 6. 228/Rjt/2023 2019-20 Deputy Commissioner M/S Maruti Enterprise Of Income-Tax, Central

Section 250

153C/ 143(3)/ 144 of the Act. 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. 3. The revenue has filed the following appeals, which pertain to partnership - firms: (i). M/s Shubham Enterprises