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3,175 results for “transfer pricing”+ Section 54clear

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Key Topics

Addition to Income73Section 143(3)51Section 153C35Section 13233Section 6931Deduction31Section 139(1)30Search & Seizure29Disallowance26Section 263

TARUN KUMAR RATAN SINGH RATHI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 32(1), MUMBAI

ITA 2695/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Jan 2024AY 2015-16
Section 143(1)Section 143(3)Section 250Section 54

price by payment in kind or adjustment towards a debt or for\nother monetary consideration. Therefore, for the purpose of\napplicability of section 54, registration of document is not\nimperative.\n9. The appellant submits that for the purpose of section 54 of the\nAct what has to be seen is whether the appellant has invested the\ncapital gains toward

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

Showing 1–20 of 3,175 · Page 1 of 159

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25
Section 14A21
Section 4019

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

transfer pricing adjustment proposed by the Learned TPO in individual transaction becomes non-est and to be quashed. Further that, as TPO’s order is non-est in the eyes of law, then the assessee could no longer be treated as eligible assessee and the draft assessment order also could not have been passed and finally the Assessment Officer

FAROOQ ABDULLA MERCHANT,MUMBAI vs. ITO 23 (1)(4), MUMBAI

In the result, Ground No. V raised by the assessee is partly allowed

ITA 7906/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 May 2023AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Blefarooq Abdulla Merchant V. Income Tax Officer- Ward – 23(1)(4) Matru Mandir, Tardev Road A-1401, Poseidon Tower Mumbai – 400 007 Versova, Yari Road Above Indian Bank, Versova Andheri (W), Mumbai - 400061 Pan: Ahupm7426K (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punamiya Department Represented By : Smt. Vranda U. Matkarni

Section 143(2)Section 54Section 54(1)

transfer took place. To reiterate in the aforesaid definition nowhere specified one residential house, definitely we can invest in more than one residential house. Plain reading of the provision of section 54(1) of the Income Tax Act disclose that when an individual assessee or HUF-assessee sells a residential building or land appurtenant thereto he can invest capital gain

LANXESS INDIA P.LTD,THANE vs. DCIT CIR 1, THANE

In the result, the appeal of the assessee

ITA 1035/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Feb 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Shri Dhanesh Bafna/Chandni

section 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in agreement with the working made by the assessee. The agreement with the working made by the assessee. The agreement with the working made

DCIT CIR 1, THANE vs. LAXCESS INDIA P.LTD, THANE

In the result, the appeal of the assessee

ITA 1697/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Feb 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Shri Dhanesh Bafna/Chandni

section 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in agreement with the working made by the assessee. The agreement with the working made by the assessee. The agreement with the working made

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

Section 92CSection 92C(3)

54,021 related to Employee Stock Option Plan (ESOP) under section 37(1) of the Act. 3.2 On the facts and in the circumstances of the case, and in law, the Ld. AO and Hon'ble DRP erred in not allowing the additional claim made during the course of assessment proceedings for ESOP expenses (being difference between market price

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

transfer pricing adjustment. In addition the Assessing Officer also proposed other additions/disallowances as per the provisions of the Act. 3.2. The Assessee filed objections before the DRP against the Draft Assessment Order, dated 31/03/2015. On 22/12/2015, the DRP disposed off the objections granting partial relief to the Assessee. As per the directions of the DRP, the Assessing Officer passed

SHAPOORJI PALLONJI AND COMPANY PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Section 115JB of the Act. 50. Aggrieved by the Assessment Order, the Assessee preferred appeal before the Learned CIT(A). The Learned CIT(A) vide Order, dated 23/12/2024, provided partial relief in respect of the transfer pricing adjustment. The Learned CIT(A) deleted the Transfer Pricing Assessment Year 2012-2013 & 2013-2014 Addition of INR.10,45,07,474/- made

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Section 115JB of the Act. 50. Aggrieved by the Assessment Order, the Assessee preferred appeal before the Learned CIT(A). The Learned CIT(A) vide Order, dated 23/12/2024, provided partial relief in respect of the transfer pricing adjustment. The Learned CIT(A) deleted the Transfer Pricing Assessment Year 2012-2013 & 2013-2014 Addition of INR.10,45,07,474/- made

DCIT, KOL. , KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 286/KOL/2023[2019-20]Status: DisposedITAT Kolkata14 Dec 2023AY 2019-20

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.286/Kol/2023 Assessment Year: 2019-20 Dcit, Kolkata.................................................................................Appellant Vs. Rungta Mines Ltd.................................................……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata – 700017. [Pan: Aabcr6463N] Appearances By: Shri Raman Garg, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing :October 18, 2023 Date Of Pronouncing The Order : December 14, 2023 आदेश / Order संजय गग", "या"यकसद"य"वारा/ Per Sanjay Garg: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 20.01.2023 Of The Commissioner Of Income Tax (Appeals)-22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Revenue In This Appeal Has Taken The Following Grounds Of Appeal: “1. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Has Erred In Not Appreciating That Arm'S Length Price & Fair Market Value Are Two Different Concepts & The Role Of The Tpo Is Limited To Determination Of Arm'S Length Price

Section 250Section 80Section 80ISection 92BSection 92F

section 92F of the Income Tax Act. He has also referred to the decision of the Hon’ble Calcutta High Court in the case of CIT vs. ITC Ltd. (2015) 64 taxman.com 2014 and therefore, has submitted that the impugned order of the CIT(A) be set aside and that of the Assessing Officer be restored. 7. On the other

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/110/2014HC Delhi11 Dec 2015
Section 260ASection 92C

54. The Court finds that the Division Bench in Sony Ericsson had occasion to deal with this very issue. In Sony Ericsson in para 156 after discussing the issue it was observed as under: “156. A Division Bench of Delhi High Court in the writ petition challenging the Transfer Pricing Order had dealt with transfer pricing issues and had enrolled

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/710/2015HC Delhi11 Dec 2015
Section 260ASection 92C

54. The Court finds that the Division Bench in Sony Ericsson had occasion to deal with this very issue. In Sony Ericsson in para 156 after discussing the issue it was observed as under: “156. A Division Bench of Delhi High Court in the writ petition challenging the Transfer Pricing Order had dealt with transfer pricing issues and had enrolled

DCIT CC-1(3),KOLKATA, KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 801/KOL/2023[2017-18]Status: DisposedITAT Kolkata15 Dec 2023AY 2017-18

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.801&802/Kol/2023 Assessment Years: 2017-18 & 2018-19 Dcit, Cc-1(3), Kolkata …….........................................................……Appellant Vs. Rungta Mines Ltd..........................................……........……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata- 700017. [Pan: Aabcr6463N] Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. Dutta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 20, 2023 Date Of Pronouncing The Order : December 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 31.05.2023 Of The Commissioner Of Income Tax (Appeals) – 22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Facts & Issues Involved In Both The Appeals Are Common & The Same Have Been Heard Together, Therefore, These Are Being Adjudicated By This Common Order. Ita No.801/Kol/2023 Is Taken As The Lead Case. 2. Ita No.801/Kol/2023 – The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 250Section 80Section 80ISection 92BSection 92F

section 92F of the Income Tax Act. He has also referred to the decision of the Hon’ble Calcutta High Court in the case of CIT vs. ITC Ltd. (2015) 64 taxman.com 2014 and therefore, has submitted that the impugned order of the CIT(A) be set aside and that of the Assessing Officer be restored. 7. On the other

DCIT, CC-1(3), KOLKATA, KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 802/KOL/2023[2018-19]Status: DisposedITAT Kolkata15 Dec 2023AY 2018-19

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.801&802/Kol/2023 Assessment Years: 2017-18 & 2018-19 Dcit, Cc-1(3), Kolkata …….........................................................……Appellant Vs. Rungta Mines Ltd..........................................……........……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata- 700017. [Pan: Aabcr6463N] Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. Dutta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 20, 2023 Date Of Pronouncing The Order : December 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 31.05.2023 Of The Commissioner Of Income Tax (Appeals) – 22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Facts & Issues Involved In Both The Appeals Are Common & The Same Have Been Heard Together, Therefore, These Are Being Adjudicated By This Common Order. Ita No.801/Kol/2023 Is Taken As The Lead Case. 2. Ita No.801/Kol/2023 – The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 250Section 80Section 80ISection 92BSection 92F

section 92F of the Income Tax Act. He has also referred to the decision of the Hon’ble Calcutta High Court in the case of CIT vs. ITC Ltd. (2015) 64 taxman.com 2014 and therefore, has submitted that the impugned order of the CIT(A) be set aside and that of the Assessing Officer be restored. 7. On the other

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 1916/MUM/2024[2012]Status: DisposedITAT Mumbai22 Oct 2024

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

For Appellant: Mr. Rajesh SanghaviFor Respondent: 20/08/2024
Section 271GSection 92Section 92CSection 92D

section 92C(1). of the method prescribed under section 92C(1). 38. The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice prevailing in the in the diamond industry separate identity of the diamond

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

ITA 1518/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Manish Kumar Kanth, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 1Section 92CSection 92C(3)

transferred company, i.e., Tata Sons Ltd. He also pointed out to the difference in logo and trade mark as noted by ld. TPO in his order. It was thus, contended that brand of “Tata Consultancy Services” is owned by the assessee and not by Tata Sons Ltd. Thus, assessee has got its own brand value and has incorporated its valuation

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 80ISection 92BSection 92C

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

DCIT CIR 15(3)(1), MUMBAI vs. TRANSOCEAN DRILLING SERVICES (INDIA) PLT, MUMBAI

In the result, the cross objection of the assessee is partly allowed

ITA 2988/MUM/2019[2012-13]Status: DisposedITAT Mumbai28 Mar 2023AY 2012-13
Section 143(2)Section 143(3)Section 92F

Transfer Pricing as enshrined in Section 92F(ii) that no unrelated party in uncontrolled circumstances would have passed on such huge contract amount exceeding Rs.622.57 Crores without charging or retaining any commission." 4. "On the facts and in the circumstances of the case and in law, the Ld.CIT(A) erred in not appreciating the fact that, the name lending