BharatTax.net
SearchITATHigh CourtsSupreme CourtAI 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.

1,428 results for “transfer pricing”+ Section 263clear

Sorted by relevance

Mumbai354Delhi264Bangalore103Chennai103Hyderabad61Ahmedabad59Kolkata59Jaipur53Pune47Rajkot45Chandigarh44Indore42Surat27Visakhapatnam23Lucknow21Raipur20Agra19Cuttack16Nagpur16Guwahati16Jodhpur15Cochin7Varanasi6Amritsar3Dehradun2Ranchi1Patna1Panaji1

Key Topics

Section 263200Section 143(3)112Addition to Income50Section 14A35Disallowance33Deduction25Section 143(2)21Section 14720Transfer Pricing18Section 142(1)

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2004/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act and held that the impugned order of the learned transfer-pricing officer is erroneous insofar as it is prejudicial to the interest of the revenue. He directed the learned transfer-pricing officer to make fresh order under section

Showing 1–20 of 1,428 · Page 1 of 72

...
17
Revision u/s 26317
Section 69B16

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act and held that the impugned order of the learned transfer-pricing officer is erroneous insofar as it is prejudicial to the interest of the revenue. He directed the learned transfer-pricing officer to make fresh order under section

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2003/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act and held that the impugned order of the learned transfer-pricing officer is erroneous insofar as it is prejudicial to the interest of the revenue. He directed the learned transfer-pricing officer to make fresh order under section

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act and held that the impugned order of the learned transfer-pricing officer is erroneous insofar as it is prejudicial to the interest of the revenue. He directed the learned transfer-pricing officer to make fresh order under section

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

transfer price of an undeclared and unreported international transaction. The TPO must justify and establish that there was an international transaction. Satisfaction of the conditions can be also inferred from the findings recorded by the TPO. Only when these conditions are satisfied, the TPO would exercise his jurisdiction. Whether or not the said conditions are satisfied in a given case

3I INFOTECH LIMITED,MUMBAI vs. PR. CIT- 15, MUMBAI

In the result, appeal of the assessee is allowed

ITA 3705/MUM/2019[2013-14]Status: DisposedITAT Mumbai10 May 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm 3I Infotech Limited Pcit-15 Tower No.5, 5Th Floor, Aaykar Bhavan, 3Rd To 6Th Floors, Vs. International Infotech Park, Mumbai-400 020 Vashi, Navi Mumbai-400 703 (Appellant) (Respondent) Pan No. Aaaci5205Q Assessee By : Shri Bhupendra Karkhanis, Shri Jay Dharod, Ars Revenue By : Ms. Samruddhi Hande, Dr Date Of Hearing: 17.02.203 Date Of Pronouncement : 10.05.2023

For Appellant: Shri Bhupendra KarkhanisFor Respondent: Ms. Samruddhi Hande, DR
Section 143(3)Section 144C(3)Section 263Section 263(1)

Transfer Pricing Officer (TPO) for determination of Arm's Length Price and the reasons assigned for doing so are wrong and contrary to the facts and circumstances of the case, provisions of the Income Tax Act, 1961, and the Rules made there under. (b) The Id. Pr. Commissioner of Income Tax erred in invoking the revisionary powers under section 263

JMJ GANPATIJI MAHARAJA HOSPITALITY PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI

In the result, both the appeal

ITA 3522/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Respondent: Mr. Rajeev Khandelwal
Section 132(1)Section 143(3)Section 153ASection 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it shall be deemed to be erroneous in so far as it is prejudicial to the interests of the is prejudicial to the interests of the revenue, if, in the opinion of the Principal revenue, if, in the opinion of the Principal

JMJ GANPATIJI MAHARAJA HOSPITALITY PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI

In the result, both the appeal

ITA 3521/MUM/2025[2012-13]Status: DisposedITAT Mumbai20 Jan 2026AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Respondent: Mr. Rajeev Khandelwal
Section 132(1)Section 143(3)Section 153ASection 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it shall be deemed to be erroneous in so far as it is prejudicial to the interests of the is prejudicial to the interests of the revenue, if, in the opinion of the Principal revenue, if, in the opinion of the Principal

K.G. DENIM LIMITED,COIMBATORE vs. DCIT, TP-2(1), CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 1718/CHNY/2024[2020-21]Status: DisposedITAT Chennai05 Dec 2024AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1718/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 K G Denim Limited, Dcit, 1, Thenthirumalai, V. Tp-2(1), Jadayampalayam B.O., Chennai. Dhoddabavi, Coimbatore – 641 302. [Pan: Aaack-7940-C] (अपीलाथ"/Assessee) (""यथ"/Respondent) अपीलाथ" क" ओर से/Assessee By : Shri. Arjun Raj, Advocate : Shri. A. Sasikumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 11.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.12.2024

For Appellant: Shri. Arjun Raj, Advocate
Section 263Section 263(1)(c)Section 801A

Section 263 of the Act by the CIT(TP), Chennai in setting aside the transfer pricing order passed under Section

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

ITA 884/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

transferring pre-paid talk time and connections and accordingly the discount extended was not income earned by the distributors. 7.2. In the Draft Assessment Order, dated 31/03/2015, the Assessing Officer proposed disallowance under Section 40(a)(ia) of the Act on the upfront discount extended to the pre-paid distributors by terming the arrangement as 'Principal to Agent instead

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

In the result, the appeal, filed by the assessee is partly allowed

ITA 2216/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

section 263, clause (c) reads as follows:- "where any order referred to in this subsection and passed by the Assessing Officer [or the Transfer Pricing

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

In the result, the appeal, filed by the assessee is partly allowed

ITA 2217/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

section 263, clause (c) reads as follows:- "where any order referred to in this subsection and passed by the Assessing Officer [or the Transfer Pricing

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

In the result, the appeal, filed by the assessee is partly allowed

ITA 2218/DEL/2025[2019-20]Status: DisposedITAT Delhi05 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

section 263, clause (c) reads as follows:- "where any order referred to in this subsection and passed by the Assessing Officer [or the Transfer Pricing

BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

ITA 1108/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21
Section 143Section 263Section 56Section 80P

Transfer Pricing\nOfficer\" shall have the same meaning as assigned to in the\nExplanation to section 92CA.]\n[(2) No order shall be made under sub-section (1) after the expiry of\ntwo years from the end of the financial year in which the order sought\nto be revised was passed.]\n(3) Not withstanding anything contained in sub-section

PHILIPS FOODS INDIA PRIVATE LIMITED,TUTICORIN vs. PCIT-1, MADURAI

In the result, the appeal of the assesse is allowed

ITA 640/CHNY/2023[2016-17]Status: DisposedITAT Chennai30 Sept 2024AY 2016-17
Section 143(3)Section 263Section 92C

pricing.", "held": "The Tribunal held that the PCIT, Madurai-1, passed the impugned order under section 263 without valid jurisdiction. The amendment to section 263, effective from April 1, 2022, specifies that only a principal chief commissioner or chief commissioner or commissioner having jurisdiction over transfer

KKR INDIA ADVISORS PVT. LTD.,MUMBAI vs. PR. CIT - CIRCLE -6, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3246/MUM/2019[2013-14]Status: DisposedITAT Mumbai13 Sept 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Kkr India Advisors Private Pr. Commissioner Of Income Limited 2Nd Floor, Piramal Tower, Tax, Circle 6 515, Aaykar Bhavan, Peninsula Corporate Park, Vs. Ganpatrao Kadam Marg, Maharshi Karve Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aadck5826G

For Appellant: Gunjan Kakkad, ARFor Respondent: Vachaspati Tripathi, CIT (DR)
Section 143(3)Section 153Section 263Section 92C

263 of the Act, the learned Assessing Officer on 26 June 2019 referred the international transaction to the learned Transfer Pricing Officer with direction of the learned PCIT. Consequent to that, the learned Transfer Pricing Officer passed an order under Section

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

ITA 416/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh22 May 2024AY 2017-18

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

For Appellant: Shri Rajiv Kaushal &For Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 263(1)Section 68Section 92C

section 263 which is as below is placed. 263. (1) The Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer or the Transfer Pricing

IDEMIA SYSCOM INDIA PRIVATE LIMITED,NOIDA vs. CIT(TP), DELHI-2, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 647/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Mar 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri M.S. Syali, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT- DR
Section 263Section 92C

Section 263 of the Act reads as under: “263. Revision of orders prejudicial to revenue. (1)The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer [or the Transfer Pricing

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

transfer of long term securities (Penny stock shares) - Assessment year 2014-\n15 - Whether before exercise of power under section 263 it is Principal Commissioner\nwho has to apply its mind to issue and thereafter record reasons as to how twin conditions\nof order of Assessing Officer being erroneous and prejudicial to interest of revenue are\nsatisfied and then issue

ALLIANCE NIRMAAN LIMITED,BAREILLY vs. PCIT, BAREILLY

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18
Section 143(3)Section 263

price or all\nsignificant risks and rewards of ownership have been transferred to the buyer and the seller\nretains no effective control of the goods transferred to a degree usually associated with\nownership; and\n(ii) no significant uncertainty exists regarding the amount of the consideration that will be\nderived from the sale of goods. Further In a transaction involving