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13 results for “transfer pricing”+ Section 13(8)clear

Sorted by relevance

Delhi4,854Mumbai4,380Bangalore1,859Chennai901Kolkata796Hyderabad704Ahmedabad688Pune678Karnataka460Jaipur431Chandigarh297Surat288Indore267Cochin209Visakhapatnam129Rajkot106SC104Cuttack81Telangana74Nagpur72Lucknow67Calcutta66Raipur64Amritsar45Agra37Guwahati36Dehradun32Jodhpur29A.K. SIKRI ROHINTON FALI NARIMAN15Ranchi13Jabalpur12Panaji12Varanasi11Rajasthan11Kerala10Patna8Allahabad8Orissa6Punjab & Haryana3DIPAK MISRA V. GOPALA GOWDA1D.K. JAIN JAGDISH SINGH KHEHAR1MADAN B. LOKUR S.A. BOBDE1Andhra Pradesh1A.K. SIKRI N.V. RAMANA1T.S. THAKUR ROHINTON FALI NARIMAN1

Key Topics

Section 143(3)13Addition to Income11Section 406Section 2635Section 1474Section 1483Transfer Pricing3Section 542Long Term Capital Gains

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 136/RAN/2015[2009-10]Status: DisposedITAT Ranchi08 Jul 2020AY 2009-10

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

ACIT, RANCHI vs. M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

2
Short Term Capital Gains2
Disallowance2
ITA 137/RAN/2015[2010-11]Status: DisposedITAT Ranchi08 Jul 2020AY 2010-11

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 125/RAN/2015[2008-09]Status: DisposedITAT Ranchi08 Jul 2020AY 2008-09

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 126/RAN/2015[2009-10]Status: DisposedITAT Ranchi08 Jul 2020AY 2009-10

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 127/RAN/2015[2010-11]Status: DisposedITAT Ranchi08 Jul 2020AY 2010-11

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 131/RAN/2015[2008-09]Status: DisposedITAT Ranchi08 Jul 2020AY 2008-09

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

8) of Section 80IA, observed that it was clear that one had to take the consideration at the market value which in relation to any goods or services, means the price that such goods or services would ordinarily fetch in the open market. The AO observed that the energy rate of JSEB inherently not only takes into account its cost

TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

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

ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

Transfer Pricing Officer was of the view that the license granted by Cummins to the assessee included any R&D development done by Tata Cummins Vs DCIT the assessee on the engine technology and the patents which was owned by Cummins and therefore, the R&D developments that has been done by the assessee was owned by Cummins Incorporated

TIMKEN INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, appeal of the assessee stands partly allowed

ITA 92/RAN/2022[2017-18]Status: DisposedITAT Ranchi12 Jun 2025AY 2017-18

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: S/Shri K.M.Gupta/Krishan Shaw, ARsFor Respondent: Smt. Rinku Singh, CIT DR
Section 115JSection 14ASection 234D

section 115-O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. Nevertheless, we are conscious of the sovereign's prerogative to extend the treaty protection to domestic companies paying dividend distribution tax through the mechanism of DTAAs. Thus, wherever

ASHOK BEHL,RANCHI vs. ITO,WARD-1(1), RANCHI

In the result, appeal filed by the assessee is allowed

ITA 78/RAN/2019[2014-15]Status: DisposedITAT Ranchi10 Sept 2020AY 2014-15

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Ashok Behl Vs. Ito, Ward-1(1), Ranchi 1St Floor, Samridhi Complex, South Office Para, Doranda, Ranchi – 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Adwpb2438E (अपीलाथ" /Appellant) .. (""थ" / Respondent)

For Appellant: Shri D. Sannigarh, ARFor Respondent: Shri A. K. Mohanti, Addl. CIT, Sr. DR
Section 143(3)

price paid or promised or part-paid and part-promised. (ii) Such transfer, in the case of tangible immoveable property or in the case of reversion or other intangible thing, can be made only by a registered instrument. (iii) Delivery of tangible immoveable property takes place when the seller places the buyer, or such person as he directs, in possession

M/S USHA MARTIN LTD,KOLKATA vs. ACIT CIR-3, RANCHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 68/RAN/2017[2007-08]Status: DisposedITAT Ranchi12 Jun 2025AY 2007-08

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: S/Shri Aditya Hans/Vishal Jain and Ashis JainFor Respondent: Smt. Rinku Singh, CIT DR
Section 234Section 244A

8. Coming to additional Ground No.1.6, same is against interest under section 244A of the Act. No arguments have been placed. Ground No.1.7 is against interest under section 234 B and 234D, theseare consequential in nature. Consequently, additional grounds raised by the assessee stand disposed as per the above direction. 9. Now coming to the main appeal filed the assessee

SUNITA ADUKIA,RANCHI vs. DCIT CIR-2, RANCHI

In the result, appeal is partly allowed

ITA 15/RAN/2018[13-14]Status: DisposedITAT Ranchi30 Oct 2019

Bench: S/Shri Chandra Mohan Gargassessment Year: 2013-14

For Appellant: Shri Rajiv Ranjan Mittal, CAFor Respondent: Shri P.K.Mondal, Addl. CIT(DR)
Section 132Section 143(3)Section 153Section 153ASection 54

price. (iv) For that the order passed u/s 143(3) of the Income Tax Act, 1961, treating the Long Term Capital Gains as Short Term Capital Gain is bad in law as well as in facts and against the Principles of natural justice and therefore liable to be set aside. P a g e 2 | 17 ITA No.14 & 15/Ran/2018 Assessment

ASHOK KUMAR PANDEY,DHANBAD vs. PR. CIT, DHANBAD

In the result, this appeal of assessee is allowed

ITA 11/RAN/2022[2017-18]Status: DisposedITAT Ranchi24 Mar 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 143(1)Section 143(2)Section 143(3)Section 263

13,750/- for the assessment year under consideration. The return was duly processed under Section 143(1) of the Act and subsequently the case was selected for complete scrutiny through CASS on specific reason i.e. "Real Estate business with high closing stocks". Statutory notices under Section 143(2) and 142(1) of the Act were issued from time to time

OM PRAAKSH SINGH,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, appeal filed by the assessee is allowed

ITA 361/RAN/2018[2009-10]Status: DisposedITAT Ranchi10 Sept 2020AY 2009-10

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Om Prakash Singh Vs. Dcit, Circle-1, Ranchi Sankalp, East Jail Road, Ranchi- 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agkps0300D (अपीलाथ" /Appellant) .. (""थ" / Respondent)

For Appellant: Shri Manjit Verma, A/RFor Respondent: Shri A. K. Mohanti, JCIT, Sr. DR
Section 142(1)Section 143(3)Section 147Section 148Section 234CSection 263Section 37(1)

13,036/- 3. Brief facts qua the issue are that assessee under consideration is a Contractor and owns a proprietorship concern in the name of M/s Prakash Construction Company.In this case, the original assessment was made by the Assessing Officer u/s 143(3) of the Act on 19.12.2011..Thereafter the Assessing Officer issued notice