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1,048 results for “charitable trust”+ Transfer Pricingclear

Sorted by relevance

Karnataka247Mumbai142Delhi116Chennai82Hyderabad62Bangalore55Jaipur37Pune37Cochin36Lucknow35Chandigarh33Ahmedabad25Kolkata22Calcutta16Visakhapatnam13Amritsar13Rajkot11Surat10Indore7Agra7Telangana5SC5Cuttack5Kerala5Varanasi4Jodhpur3Nagpur3Allahabad3Rajasthan3Raipur2T.S. THAKUR ROHINTON FALI NARIMAN1Punjab & Haryana1Andhra Pradesh1Dehradun1

Key Topics

Section 11125Section 2(15)58Addition to Income53Section 12A52Exemption46Section 143(3)42Section 80G(5)38Section 80G36Section 153C35Section 10

SHRI SHESHAVTAR 1008 SHRI KALLAJI VEDPITH EVAM SHODH SANSTHAN,NIMBAHERA, CHITTORGARH vs. ITO EXEMPTION WARD, UDAIPUR, AAYKAR BHAWAN, UDAIPUR

In the result, appeal of the assessee is partly allowed

ITA 268/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Apr 2025AY 2017-18

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Sunil Surana, CA &For Respondent: Shri Karni Dan, Addl. CIT, Sr.DR
Section 115BSection 12ASection 142Section 143(1)Section 143(2)Section 234BSection 234DSection 250

transfer pricing study. In view of the aforenoted discussion and the ratio of the these precedents, we direct the AO/TPO to examine the correctness of the figures placed on record by the assessee in support of its contention that the case of Goldstone Teleservices Ltd. was wrongly included by it in the list of comparables, which is actually not comparable

Showing 1–20 of 1,048 · Page 1 of 53

...
19
Disallowance19
Natural Justice13

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

In the result, the appeal of the Revenue is dismissed

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17
Section 11Section 12ASection 143(3)

price permissible under prevailing stamp\nduty law. The AO further observed that the entire sale consideration was given to\nother entity as donation. Accordingly, ld. CIT DR submits that assessee is not carried\nout any charitable activity nor any income was ever derived from such land which\nwas sold during the year and further entire consideration was transferred as donation

CHIRAYU CHARITABLE FOUNDATION,BHOPAL vs. PCIT (CENTRAL), BHOPAL

In the result appeal of the assessee stands allowed

ITA 179/IND/2019[-]Status: DisposedITAT Indore09 Feb 2021

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradchirayu Charitable Pcit (Central), Foundation,Bhopal Indore Bhopal Highway, Bhaisakhedi, Vs. Bhopal (Appellant) (Revenue ) Pan No.Aaaac3656P Revenue By Shri S.S. Mantri, Cit Appellant By S/Shri Sumit Nema, Sr. Advocate, Gagan Tiwari & Piyush Parashar, Advs Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R Per Manish Borad, Am.

Section 12ASection 132

transferred to the groups donation account through a journal entry passed on 29.8.2011. The assessment of the assessee was completed u/s 143(3) of the Act for Assessment Year 2011-12 on 18.3.2014 in normal course and during the course of proceedings confirmation of loan creditors were filed, copy of bank account of M/s Riviera Infoway Ltd along with

BALLARAM HANUMANDAS CHARITABLE TRUST,KOLKATA vs. CIT(EXEMPTIONS), KOL., KOLKATA

In the result, appeal of assessee stands allowed

ITA 431/KOL/2017[2012-13]Status: DisposedITAT Kolkata15 Sept 2017AY 2012-13

Bench: Shri Aby.T Varkey & Shri Waseem Ahmedassessment Year :2012-13

Section 12ASection 133Section 35(1)(ii)

transferring the same in the form of donation through the web of financial transactions. In either case, SHG & PH was charging commission for providing the above stated accommodation entries. During survey at SHG & PH it was ascertained that assessee-trust has received donation amounting to ₹68.50 lakh from SHG & PH through banking channel against the cash provided

BHARATPUR ROYAL FAMILY RELIGIOUS & CEREMONIAL TRUST,BHARATPUR vs. CIT(E), JAIPUR

In the result, we upheld the order of the ld PCIT in exercise of his powers u/s 263 in setting aside the order so passed by the AO and the grounds of appeal taken by the assessee are hereby dismissed

ITA 290/JPR/2020[2011-12]Status: DisposedITAT Jaipur13 Jul 2021AY 2011-12
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Rajendra Singh (CIT)
Section 10Section 12ASection 154Section 24Section 263Section 297

charitable purposes. Therefore, provisions of sections 11 & 12 do not disturb the head of the income which are otherwise 35 Bharatpur Royal Family Religious & Ceremonial Trust Moti Mahal, Bharatpur Vs. CIT(E), Jaipur applicable in respect of a particular income based on its source. The capital gain which is arising from the investment of the Trust which is otherwise permissible

ACIT, EXEMPTIONS, COIMBATORE vs. MAHENDRA EDUCATIONAL TRUST, MANAKKAL

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

ITA 126/CHNY/2019[2012-13]Status: DisposedITAT Chennai11 Feb 2021AY 2012-13

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri G. Chandrababu, Addl.CIT
Section 1Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 13(2)(h)Section 13(3)

transferred to M/s. Star Educational 22 I.T.A. Nos. 125 &126/CHNY/2019 & CO Nos. 18 & 19/CHNY/2019 Further, out of the total advance of Rs.10,24,860/-, a sum of Rs.1,74,720/- was considered as donation given to said trust and balance amount of Rs.8,50,140/- as repayable to the trust. Therefore, merely for the reason that advance given to another

ACIT, EXEMPTIONS, COIMBATORE vs. MAHENDRA EDUCATIONAL TRUST, MANAKKAL

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

ITA 125/CHNY/2019[2011-12]Status: DisposedITAT Chennai11 Feb 2021AY 2011-12

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri G. Chandrababu, Addl.CIT
Section 1Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 13(2)(h)Section 13(3)

transferred to M/s. Star Educational 22 I.T.A. Nos. 125 &126/CHNY/2019 & CO Nos. 18 & 19/CHNY/2019 Further, out of the total advance of Rs.10,24,860/-, a sum of Rs.1,74,720/- was considered as donation given to said trust and balance amount of Rs.8,50,140/- as repayable to the trust. Therefore, merely for the reason that advance given to another

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 308/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Aug 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 345/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Aug 2023AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

ACIT 17(1) , MUMBAI vs. MAHINDRA & MAHINDRA EMPLOYEES STOCK OPTION TRUST, MUMBAI

In the result, both the appeals of the Revenue are dismissed

ITA 1120/MUM/2022[2016-17]Status: DisposedITAT Mumbai04 Aug 2022AY 2016-17
Section 112Section 143(3)Section 250

price. Under such circumstances, the assessee trust is not in a position to earn maximum profits. Thus, it shares. The shares held by the assessee trust cannot be categorised as „stock- in-trade‟ of the assessee trust. 5.14. There is one more angle to decide this issue. We have examined and visualized that what would have been the character

ACIT-17(1), MUMBAI, MUMBAI vs. MAHINDRA & MAHINDRA EMPLOYEES STOCK OPTION TRUST., MUMBAI

In the result, both the appeals of the Revenue are dismissed

ITA 1119/MUM/2022[2013-14]Status: DisposedITAT Mumbai04 Aug 2022AY 2013-14
Section 112Section 143(3)Section 250

price. Under such circumstances, the assessee trust is not in a position to earn maximum profits. Thus, it shares. The shares held by the assessee trust cannot be categorised as „stock- in-trade‟ of the assessee trust. 5.14. There is one more angle to decide this issue. We have examined and visualized that what would have been the character

M/S. UNITED SPIRITS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the assessee is partly allowed

ITA 489/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 May 2020AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleit(Tp)A No.489/Bang/2017 (Assessment Year: 2012-13) M/S. United Spirits Limited, Ub Towers, No.24, Vittal Mallya Road, Bangalore-560 001 ….Appellant Vs. Dy. Commissioner Of Income Tax, Circle 7(1)(1), Bangalore. ……Respondent. Assessee By: Shri Perci Pardiwala, Senior Advocate & Shri Ketan Ved, C.A. Revenue By: Shri Bipin C.N, Jcit (D.R) Date Of Hearing : 06.03.2020. Date Of Pronouncement : 29.05.2020. O R D E R Per Shri B.R. Baskaran, A.M. : The Assessee Has Filed This Appeal Challenging The Assessment Order Dated 31-01-2017 Passed By The Assessing Officer For Assessment Year 2012-13 Passed U/S 143(3) R.W.S 144C(13) Of The Act.

For Appellant: Shri Perci Pardiwala, Senior Advocate and Shri Ketan Ved, C.AFor Respondent: Shri Bipin C.N, JCIT (D.R)
Section 143(3)Section 144C(10)Section 144C(13)Section 14ASection 154Section 36(1)(iii)Section 92C

transfer pricing provision and not while allowability of business expense u/s 37(1). It is well known fact that companies use sports event as a platform to advertise their range of products as it has a very high viewership. Any such incurring of expenditure is ostensibly for 34 IT(TP)A No.489/Bang/2017 . promotion of business only and hence, no disallowance

BHAMASHAH SUNDARLAL DAGA CHARITABLE TRUST,BIKANER vs. CIT - EXEMPTION, JAIPUR

The appeal of the assessee is allowed for statistical purpose

ITA 278/JODH/2023[2022-23 to 2026-27]Status: DisposedITAT Jodhpur10 Nov 2023

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.278/Jodh/2023 िनधा"रण वष" / Assessment Year : N.A. Bhamashah Sundarlal Daga The Commissioner Of Charitable Trust, V Income Tax-Exemption, Bagree Mohallan, S Jaipur. Bikaner – 334001. Pan: Aaetb1013C Appellant/ Assessee Respondent/ Revenue Assessee By Shri Suresh Ojha – Ar Revenue By Smt. Alka Rajvanshi Jain – Cit(Dr) Date Of Hearing 14/08/2023 Date Of Pronouncement 10/11/2023

Section 12Section 12A(1)(ac)Section 80GSection 80G(5)

Charitable Trust [A] price shoots up with the result that the market price prevailing on the date of the sale exceeds the agreed price at which the property is sold by more than 15 per cent of such agreed price. This is not at all an uncommon case in an economy of rising prices and in fact we would find

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 701/LKW/2019[2017-18]Status: DisposedITAT Lucknow10 Jun 2022AY 2017-18

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

charitable trust' under Act, 1961. 50. In the case of Jaipur Development Authority, Revenue held that major source of income is sale of plots and built up properties. Remaining income is received from various charges, fees and penalties levelled and collected by Jaipur Development Authority. Jaipur Bench of Tribunal in I.T.A.No.182/JP/2012, Jaipur Development Authority, J.L.N. Marg, Jaipur

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 166/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Jun 2022AY 2016-17

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

charitable trust' under Act, 1961. 50. In the case of Jaipur Development Authority, Revenue held that major source of income is sale of plots and built up properties. Remaining income is received from various charges, fees and penalties levelled and collected by Jaipur Development Authority. Jaipur Bench of Tribunal in I.T.A.No.182/JP/2012, Jaipur Development Authority, J.L.N. Marg, Jaipur

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 165/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Jun 2022AY 2015-16

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

charitable trust' under Act, 1961. 50. In the case of Jaipur Development Authority, Revenue held that major source of income is sale of plots and built up properties. Remaining income is received from various charges, fees and penalties levelled and collected by Jaipur Development Authority. Jaipur Bench of Tribunal in I.T.A.No.182/JP/2012, Jaipur Development Authority, J.L.N. Marg, Jaipur

RAKESHBHAI KARSANBHAI PATEL,AHMEDABAD vs. DCIT, CIRCLE-3(1)(1), AHMEDABAD

ITA 635/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad23 Sept 2019AY 2009-10
For Appellant: Shri S.N. Soparkar &For Respondent: Shri L.P. Jain, Sr. D.R
Section 143(2)Section 143(3)

charitable trust and there is no evidence for actual transfer of shares to Trust. Further, the AO observed that shares have been sold off-market at token price

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. AHMEDABAD URBAN DEVELOPMENT AUTHORITY

C.A. No.-021762-021762 - 2017Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

transfer of rights for performing and undertaking regulatory or administrative duties for general public interest, when these are not guided and undertaken with profit motive or intent. Further, reliance was placed on The Commissioner of Income Tax (Exemptions), Chandigarh v. M/s Hoshiarpur Improvement Trust, Hoshiarpur64 to explain the characteristics of the assessee. Learned counsel further laid emphasis on provisions

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

ITA - 53 / 2000HC Delhi09 Jul 2012
For Appellant: Mr Ajay Vohra and Ms Kavita JhaFor Respondent: Mr Sanjeev Sabharwal and Ms Suruchi Aggarwal
Section 201

charitable activities. The lease rent was revised from Rs 25,000/- to Rs 50,000/- per month with effect from 01.04.1987 and further to Rs 1,00,000/- per month with effect from 01.04.1989. The lease deed further shows that even after selling its production unit „Mahesh Udoyog‟ to the assessee, the Trust continued to be engaged in manufacturing

COMMISSIONER OF INCOME TAX DEL vs. M/S SHANKAR TRADING CO. P. LTD

The appeals stand disposed of

ITA - 247 / 2002HC Delhi09 Jul 2012
For Appellant: Mr Ajay Vohra and Ms Kavita JhaFor Respondent: Mr Sanjeev Sabharwal and Ms Suruchi Aggarwal
Section 201

charitable activities. The lease rent was revised from Rs 25,000/- to Rs 50,000/- per month with effect from 01.04.1987 and further to Rs 1,00,000/- per month with effect from 01.04.1989. The lease deed further shows that even after selling its production unit „Mahesh Udoyog‟ to the assessee, the Trust continued to be engaged in manufacturing