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15 results for “transfer pricing”+ Section 4clear

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Key Topics

Section 143(3)14Addition to Income12Section 50C7Section 69B7Section 406Section 2635Section 1474Section 1483Section 56(2)(vii)3

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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

Short Term Capital Gains3
Transfer Pricing3
Long Term Capital Gains2
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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

transferred to its other business for the purpose of computation of profits and gains of the eligible business in terms of Section 80-IA(8) of the Act." In this regard it is noted that the Hon'ble Mumbai Tribunal in the case of the West Coast Paper Mills Ltd. Vs. Asstt. Commissioner of Income

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

4 Tata Cummins Vs DCIT (ii) the expression intangible property" shall include— (b) technology related intangible assets, such as, process patents, patent applications, technical documentation such as laboratory notebooks, technical know-how .................... 9.14 At the very outset, it would be seen that under the definition of the term international transaction the purchase, sale, transfer, lease or use of intangible property

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

4 is in regard to the transfer pricing addition. Ground No.5.1 and 5.2 related to the disallowance u/s.14A r.w. Rule 8D of the Act, both under the normal provisions of the Act as well as in respect of book profit computed under section

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

SRI NALIN RANJAN,JAMSHEDPUR vs. ITO WD-1(3), JSR

In the result, appeal of the assessee is dismissed

ITA 331/RAN/2017[14-15]Status: DisposedITAT Ranchi29 Aug 2019

Bench: S/Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year: 2014-15

For Appellant: Shri Devesh Poddar, AdvFor Respondent: Shri P.K.Mondal, Addl. CIT(DR)
Section 50C

transfer of the capital asset.] From the plain reading of the section, it is clear that capital gain is chargeable in the year in which such conversion took place and capital gain is charged u/s.48 accordingly. In the instant case the conversion took place on 4.2.2010 as per the agreement entered into by and between developer and the assessee. Accordingly

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

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, [including

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

transfer pricing, it was submitted that the assessee is in the business of manufacture of steel wire, steel ropes, wire rods, billets, wires, and other steel products etc. It was the submission that the products manufactured by the assessee was in the realm of steel. The assessee had provided its TNMM calculation and had given multiple

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)

section 148 of the Act was issued to assessee on 31.12.2016. In the assessee`s case the relevant assessment year is 2009-10, therefore the assessee`s case was reopened after the expiry of 4 Years from the end of the relevant assessment year. The settled position of law is that if an assessment for any year has been completed

DCIT CIRCLE-1, RANCHI vs. SHRI ANUP CHAWLA, RANCHI

In the result, the appeal of the revenue is dismissed

ITA 8/RAN/2017[2012-13]Status: DisposedITAT Ranchi22 Feb 2019AY 2012-13

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

For Appellant: None appearedFor Respondent: Shri Chandan Das, JCIT/ld.DR
Section 143(3)Section 48Section 50CSection 56(2)(vii)Section 69B

4. Ground nos. 1 & 2 relates to deletion of addition of Rs. 1,80,52,500/- u/s. 69B r.w.s 50C of the Act. 5. Brief facts qua the issue are that assesse had purchased an immovable property for Rs. 62,10,000/- which included the price of the property at Rs. 45,00,000/- and stamp duty