BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

2,073 results for “transfer pricing”+ Revision u/s 263clear

Sorted by relevance

Mumbai419Delhi370Bangalore202Karnataka190Kolkata154Chennai125Jaipur105Ahmedabad81Pune60Hyderabad51Chandigarh50Indore44Visakhapatnam40Cochin34Rajkot28Surat22Raipur21Agra14Cuttack13Nagpur11Jodhpur9Amritsar9Lucknow8Guwahati3Jabalpur2Dehradun2Allahabad1Panaji1Patna1Rajasthan1Telangana1Kerala1

Key Topics

Section 263110Section 143(3)92Addition to Income60Section 14834Section 133A29Section 14727Disallowance26Section 14321Transfer Pricing19Section 131

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

revised to 24.97% in a rectification order passed under section 154 of the Act on 17th November 2011. Thus, on the basis of the margin computed of the comparable companies an adjustment of `239,02,52,498, was made to the arm's length price. 3. As regards ITES segment, during the proceedings before the Transfer Pricing Officer the assessee

Showing 1–20 of 2,073 · Page 1 of 104

...
16
Section 153A15
Revision u/s 26314

ESSAR SHIPPING LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 5, MUMBAI

In the result, appeal of the assessee is allowed as indicated above

ITA 3156/MUM/2018[2011-12]Status: DisposedITAT Mumbai30 Sept 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri N.K. Pradhan, Hon'Blem/S. Essar Shipping Limited V. Pr. Cit-5 Essar House, 11, K.K. Marg Room No. 501 Mahalaxmi, Mumbai – 400 034 Aayakar Bhavan, M.K. Road Mumbai-400 020 Pan: Aacce3707D (Appellant) (Respondent) Assessee By : Shri Vijay Mehta Department By : Shri D.G. Pansari

For Appellant: Shri Vijay MehtaFor Respondent: Shri D.G. Pansari
Section 143(1)Section 144C(1)Section 263Section 92C

Transfer Pricing Officer [hereinafter in short “TPO”] vide letter dated 23.10.2013. Subsequently the TPO passed an order u/s. 92CA(3) of the Act dated 22.01.2015 determining the arm’s length price of the international transactions. The final assessment order was passed on 10.04.2015 u/s.144C(1) r.w.s. 143(3) of the Act. 3 M/s. Essar Shipping Limited The Ld. Pr.CIT thereafter

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details were provided to the Transfer Pricing Officer and after examining complete details a possible view has been taken by the Transfer Pricing Officer before passing order u/s 92CA(3). • The notice issued u/s 263

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details were provided to the Transfer Pricing Officer and after examining complete details a possible view has been taken by the Transfer Pricing Officer before passing order u/s 92CA(3). • The notice issued u/s 263

M/S. AMIRA PURE FOODS PVT. LTD.,NEW DELHI vs. PR. CIT (C), GURGAON

In the result, the stay application filed by the assessee is dismissed and the appeal of the assessee in ITA No

ITA 3205/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2017AY 2014-15

Bench: Shri B.P. Jain & Shri Sudhanshu Srivastava

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Smt. Aparna Karan, CIT- DR
Section 142(1)Section 143(2)Section 143(3)Section 263

revise the assessment order passed u/s 143(3). The ld. PCIT has held that the assessment order was passed without making proper inquiries/ verification/investigations which should have been made before 3 accepting the trading results/other issues and therefore, the order is erroneous and prejudicial to the interest of revenue. The LD. PCIT issued show cause notice u/s 263

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 63/JPR/2021[2015-16]Status: DisposedITAT Jaipur07 Mar 2024AY 2015-16

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Ajey Malik, CIT
Section 10ASection 147Section 253(5)Section 263Section 5

REVISION U/S. 263 7. CIT v. Manna Trust 42 44 {2022 (01) TMI 693} Rajasthan High Court 27 Pinkcity Jewelhouse Pvt. Ltd. vs. PCIT 8. Gayatri Devi v. PCIT 45 78 {2023 (10) TMI 23} ITAT - Jaipur PAPER BOOK-II SNo. Particulars Page No. From To 1. Copy of Order dated 18.12.2017 passed u/s 147 r.w.s

PHILIPS INDIA LTD.,KOLKATA vs. PCIT-IV, KOLKATA, KOLKATA

In the result, appeal of the assessee is dismissed

ITA 1142/KOL/2016[2009-2010]Status: DisposedITAT Kolkata27 Mar 2019AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi] I.T.A. No. 1142/Kol/2016 Assessment Year: 2009-10 Philips India Limited..........……………………………………....………………..…………………….….Appellant Earlier Known As Philips Electronics India Limited 7 No. Justice Chandra Madhab Road Kolkata – 700 020 [Pan : Aabcp 9487 A] Principal Commissioner Of Income Tax - Iv, Kolkata…….............…....................…...Respondent Appearances By: Shri P.J. Pardiwala, Sr. Advocate & Shri Navneet Misra, Advocate, Appeared On Behalf Of The Assessee. Shri Robin Choudhury, Addl. Cit D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : January 10Th, 2019 Date Of Pronouncing The Order : March 27Th, 2019 O R D E R Per J. Sudhakar Reddy :-

Section 143(3)Section 263Section 32

Transfer Pricing Officer (TPO). The final assessment order was passed u/s 143(3)/144C on 01/03/2013, computing the total income at Rs.412,94,85,880/-. Subsequently the Pr. CIT-4, Kolkata issued a notice u/s 263 of the Act, on 13/11/2015 proposing revision

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1144/MUM/2022[2016-2017]Status: DisposedITAT Mumbai19 Oct 2022AY 2016-2017
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED,MUMBAI vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1139/MUM/2022[2011-12]Status: DisposedITAT Mumbai19 Oct 2022AY 2011-12
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1145/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Oct 2022AY 2017-18
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED,MUMBAI vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1138/MUM/2022[2010-2011]Status: DisposedITAT Mumbai19 Oct 2022AY 2010-2011
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISE LIMITED,MUMBAI vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1143/MUM/2022[2015-16]Status: DisposedITAT Mumbai19 Oct 2022AY 2015-16
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED ,TELAGANA vs. THE PCIT (CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1141/MUM/2022[2013-2014]Status: DisposedITAT Mumbai19 Oct 2022AY 2013-2014
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED,TELANGANA vs. THE PCIT (CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1142/MUM/2022[2014-2015]Status: DisposedITAT Mumbai19 Oct 2022AY 2014-2015
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED ,MUMBAI vs. THE PCIT(CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1137/MUM/2022[2009-10]Status: DisposedITAT Mumbai19 Oct 2022AY 2009-10
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

SOMA ENTERPRISES LIMITED,TELANGANA vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

ITA 1140/MUM/2022[2012-2013]Status: DisposedITAT Mumbai19 Oct 2022AY 2012-2013
Section 115JSection 132Section 132(4)Section 143(3)Section 14ASection 153ASection 154Section 263

Transfer Pricing Officer. We hold that the ld. PCIT is only trying to substitute his view , which is patently illegal, in the place of view already taken by the ld. AO, which, in our considered opinion, cannot be done by invoking revision jurisdiction u/s 263

M/S GOLDEN VINCOM PVT LTD,KOLKATA vs. PCIT-1, KOLKATA

In the result, the appeal of the assessee is allowed as per the terms indicated above

ITA 143/KOL/2021[2011-12]Status: DisposedITAT Kolkata27 Apr 2022AY 2011-12

Bench: Sri Sanjay Garg & Sri Manish Borad)

Section 143(3)Section 147Section 151Section 263

revising an order passed u/s 143(3) of the Act dated 30.12.2011. In the assessment u/s 143(3) of the Act the AO has observed that the assessee has received share capital and share premium of Rs.8,80,000/- and Rs.79,20,000/- respectively during the relevant previous year. He also observed that to verify the genuineness of the share

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

ITA 925/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

revised by the Ld. CIT only when it is shown that the said order is prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one has to understand what is prejudicial

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

ITA 926/CHNY/2024[2018-19]Status: DisposedITAT Chennai12 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

revised by the Ld. CIT only when it is shown that the said order is prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one has to understand what is prejudicial

SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

ITA 250/ASR/2019[2011-12]Status: DisposedITAT Amritsar19 Oct 2022AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Sudhir Sehgal & Sh. P.N. Arora, AdvFor Respondent: Sh. Amlendu Nath Misra, CIT DR
Section 143(3)Section 263

revise the said order u/s 263. Copy placed at pages 49 to 50 of the Paper Book. 10. 14.03.2019 One the basis of report of JCIT, Notice issued u/s 263 of the Act against the assessment order passed u/s 143(3)/263 on following issues: " Issue of claim of exemption of Rs. 5,12,75,000 as exempt capital gain