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4,488 results for “transfer pricing”+ Section 132(4)clear

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Key Topics

Addition to Income62Section 143(3)52Section 153A42Section 14A38Section 26332Disallowance30Section 69A25Section 153C24Section 132(4)21Section 132

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

ITA 431/BANG/2024[2013-14]Status: DisposedITAT Bangalore03 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 132Section 132(4)Section 153ASection 153DSection 234A

price being inflated cannot be ruled out and there is no material to dislodge such finding. The issue is not whether the purchase price reflected in the books of account matches the purchase price stated to have been paid to other persons. The issue is whether the purchase price paid by the assessee is reflected as receipts by the recipients

Showing 1–20 of 4,488 · Page 1 of 225

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Survey u/s 133A17

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 835/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Jun 2024AY 2014-15
For Appellant: Shri V. Srinivasan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132Section 132(4)Section 234ASection 69A

transferred to me.\nI have received salary income of around Rs.25,00,000/- which I will offer as income\nand pay resultant tax. I am not able to explain the sources for the remaining\nRs.40,00,000/-. I offer the same as my additional undisclosed income for the FY\n2013-14.\n3.1. From the above ld. AO observed that assessee

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

ITA 836/BANG/2024[2018-19]Status: DisposedITAT Bangalore12 Jun 2024AY 2018-19
Section 115BSection 132Section 132(4)Section 234A

transferred to me.\nI have received salary income of around Rs.25,00,000/- which I will offer as income\nand pay resultant tax. I am not able to explain the sources for the remaining\nRs.40,00,000/-. I offer the same as my additional undisclosed income for the FY\n2013-14.\n3.1. From the above ld. AO observed that assessee

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 725/PUN/2022[2018-19]Status: DisposedITAT Pune28 Jun 2023AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

For Appellant: Shri Ratan SamalFor Respondent: Shri Keyur Patel
Section 132(4)Section 139(1)

section 132(4) of the Income-tax Act even though retracted, the addition could be justified. The judgements are distinguishable on facts.” 25. In the light of above findings, we are of the considered opinion that the orders of the Assessing Officer as well as the ld. CIT(A) suffers from illegality and cannot be sustained in the eyes

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

transfer- pricing officer to benchmark the interest as directed. 032. Accordingly, ground number 1 of the appeal is partly allowed. 033. Ground no. 2 and 3 of the appeal with respect to not considering the sale of empty containers, etc. as profit industrial unit for the purpose of deduction under Section 80IB of the Act. 034. The brief facts shows

DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

ITA 5556/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Oct 2019AY 2007-08

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Section 250Section 92C

4. Brief facts of the case for that year shows that assessee filed its return of income on 30/10/2010 declaring loss of Rs 29905615/–. During the year, the assessee has acted like as an authorised agent for BBC worldwide Ltd (UK entity) for soliciting orders for sale of Air time, advertisement on BBC world channel, besides other market support services

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

4. The first substantive dispute in this appeal is with respect to an addition of Rs.24,91,59,200/- made by the Assessing Officer, based on the determination of arm's length price by the Transfer Pricing Officer, with respect to the international transaction of sale of TV Programmes and films to associated enterprise. The relevant facts in this regard

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1372/KOL/2017[2009-10]Status: DisposedITAT Kolkata19 Sept 2018AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

4, 6 7 and 8 are in respect of export from 10A & 10B Unit, and relate to grievance that transfer pricing provision did not apply to transaction between the 10A and 10B unit, and to reduce the turnover pertaining to sections 10A & 10B in computation of arm’s length price. Note: All the above grounds relating to transfer pricing

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1371/KOL/2017[2008-09]Status: DisposedITAT Kolkata19 Sept 2018AY 2008-09

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

4, 6 7 and 8 are in respect of export from 10A & 10B Unit, and relate to grievance that transfer pricing provision did not apply to transaction between the 10A and 10B unit, and to reduce the turnover pertaining to sections 10A & 10B in computation of arm’s length price. Note: All the above grounds relating to transfer pricing

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

pricing provision is applicable. 54 Viacom 18 Media Pvt. Ltd. 119. Considered the rival submissions and perused the material on record. We find that the issue arising out of the aforesaid ground of appeal has been decided by the Tribunal in assessee‟s own case in ACIT v/s M/s. Viacom 18 Media Pvt. Ltd., ITA no. 8406/Mum./2010, order dated

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S. KEDIA REAL ESTATE LLP, JAIPUR

In the result, appeals of the revenue are dismissed whereas appeals of the assessee are allowed in part

ITA 289/JPR/2019[2017-18]Status: DisposedITAT Jaipur03 Jun 2019AY 2017-18
For Appellant: Shri Vijay Goyal (FCA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 132(1)Section 143(3)Section 153A

Section 132(4) of the Income Tax Act, 1961, alone should not be the basis, for arriving at any adverse decision against the assessee. If the authorities under the Income Tax Act, 1961, have to be conferred with the power, to be exercised, solely on the basis of a statement, then it may lead to an arbitrary exercise of such