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898 results for “transfer pricing”+ Section 69Aclear

Sorted by relevance

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Key Topics

Addition to Income69Section 69A58Section 143(3)55Section 25044Section 153A36Section 143(2)26Section 6825Section 13225Section 14823Unexplained Investment

M/S SUPREMO INDIA LTD ,INDORE vs. THE AIT CENTRAL 3, INDORE

In the result, appeal of assessee is allowed

ITA 29/IND/2023[2019-20]Status: DisposedITAT Indore07 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Supremo India Pvt. Ltd. Acit Central-3 400/2, Halka Patwari No.52 Indore Vs. Badiakeema Dudhiya, B.O. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcs 9822 C Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 07.06.2023

Section 115BSection 131(1)Section 133ASection 69ASection 69B

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

Showing 1–20 of 898 · Page 1 of 45

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14
Search & Seizure12
Disallowance12

M/S D. N. SINGH THROUGH PARTNER DUDHESHWAR NATH SINGH vs. COMMISSIONER OF INCOME TAX

C.A. No.-003738-003739 - 2023Supreme Court16 May 2023

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

Section 260A

price, has been placed in possession of the houses as an owner and is using the buildings for the purpose of its business in its own right. Still the assessee has been denied the benefit of Section 32. On the other hand, the Housing Board would be denied the benefit of Section 32 because in spite of its being

M/S NIKHIL ESTATE P LTD,INDORE vs. THE ACIT CENTRAL CIRCLE (3) INDORE, INDORE

In the result, appeal of assessee is allowed

ITA 28/IND/2023[2019-20]Status: DisposedITAT Indore09 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Nikhil Estate Pvt. Ltd. Acit (Central)-3 M-102, Mezzanine, Floor, Indore Dhan Trident, P. No.B-3 Pu- Vs. 4, Sch. No.54, Vijay Nagar Square, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcn 8056 D Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 09.06.2023

Section 115BSection 133ASection 69Section 69B

69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions

PEEYUSH AGARWAL,JAIPUR, RAJASTHAN vs. ITO, WARD 1(5), JAIPUR, JAIPUR, RAJASTHAN

In the result Ground and 1 and 2 raised by the assessee are allowed

ITA 488/JPR/2025[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.A. &For Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 250Section 68Section 69A

section 68 of the 51 Peeyush Agarwal, Jaipur. Act that will amount to double taxation once as sales and again as unexplained cash credit which is against the principles of taxation. Assessee was having only one source of income from trading in beedi, tea power and pan masala and therefore provisions of section 115BBE of the Act will have

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

69A of the Act is unsustainable in law. The addition is made on unsubstantiated entries in some loose sheets and does not represent any money found and hence does not come under the purview of Section 69A of the Act.The addition is made out on basis of loose sheets of documents, which does not come under the ambit of ‘books

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur14 Feb 2025AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

69A of the Act. As such, the assessee was able to justify the source of income surrendered during survey operation. Therefore we are of the view that the same cannot be treated as deemed income. Once, the income goes out of the preview of the deeming provision, the provision of section 115BBE of the Act cannot be applied. 17. Thus

DEPUTY CIT-5(1)(1), MUMBAI, MUMBAI vs. M/S ESSAR SHIPPING LIMITED , MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 821/MUM/2022[2015-16]Status: DisposedITAT Mumbai14 Nov 2022AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri M Balaganesh, Am आयकरअपीलसं./ I.T.A. No. 821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2015-16) M/S Essar Shipping Dy. Cit-Circle – 5(3)(1), Limited R. No. 568, Aayakar बिधम/ Essar House, 11, K K Bhavan, M. K. Road, Vs. Marg, Mahalaxmi, Mumbai-400 020 Mumbai-400 034 स्थायीलेखासं./जीआइआरसं./ Pan No. Aacce3707D (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Prakash R. Mane, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Manoj Patwari/ Shri Rishav Patwari, Ld. Ars सुनवाईकीतारीख/ : 18.08.2022 Date Of Hearing घोषणाकीतारीख / : 14.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Impugned Order Dated 28.02.2022, Passed By Ld. Cit (Appeals)-56, Mumbai For The Quantum Of Assessment Passed U/S 143(3) R.W.S.

For Appellant: Shri Prakash R. ManeFor Respondent: Shri Manoj Patwari/ Shri
Section 115VSection 143(3)Section 28Section 43Section 92Section 92F

pricing adjustment of Rs. 1.46 crores made by the AO @ 2% which has been restricted to 0.25% by the Ld. CIT (A) in respect of negative lien provided to associated entity. 10. Assessee has given has given ‘No Lien Undertaking’ to lenders (ICICI Bank Ltd, Hong Kong Branch and Singapore Branch) of Essar Global Ltd., wherein it has undertaken that

ACIT, NUNGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

ITA 1876/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

ACIT, NUNAGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

ITA 1874/CHNY/2025[2016]Status: DisposedITAT Chennai30 Dec 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

For Appellant: Mr. Y. Sridhar, FCA
Section 132Section 132(4)Section 134(4)Section 250

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1879/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

ITA 2806/BANG/2017[2013-14]Status: DisposedITAT Bangalore02 Mar 2023AY 2013-14

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Sunil Kumar Singh, CIT (D.R)
Section 143(3)Section 92C(2)

transfer pricing adjustment should be restricted only to the AE related transactions of the assessee.” 11.3 Respectfully following the above judgment of coordinate bench of the Tribunal, we allow this ground of the assessee. Ground No.8 12. The ld.AR of the assessee submitted that Rohan Motors Ltd., and Sicagen India Ltd., were considered by the TPO as comparable companies after

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 888/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

DCIT, CENTRAL CIRCLE-3(2), , MUMBAI vs. M/S VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 890/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

DCIT, CENTRAL CIRCLE-3(2), MUMBAI vs. VIRAJ PROFILES PRIVATE LIMITED, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 871/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

Transfer Pricing Officer (TPO) noted that the assessee had not charged any commission for extending such guarantees. He was of the opinion that the transaction was an international transaction that required benchmarking, and accordingly determined the arm’s length commission at 1.5%. assessee’s income for the respective years. 6. In the first appellate stage, the learned CIT(A) examined

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 113/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69A, 69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 176/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69A, 69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 115/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69A, 69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 175/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69A, 69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 114/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69A, 69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri