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871 results for “transfer pricing”+ Section 69Cclear

Sorted by relevance

Mumbai301Delhi185Jaipur89Bangalore44Hyderabad39Indore34Chandigarh32Chennai21Kolkata21Agra19Guwahati16Ahmedabad12Surat12Pune12Nagpur9Amritsar8Jodhpur4Lucknow4Visakhapatnam4Raipur2Rajkot1Allahabad1Varanasi1

Key Topics

Addition to Income81Section 6851Section 143(3)51Section 69C49Section 13246Section 10(38)38Section 153A38Section 153C36Section 6935Search & Seizure

ADD ADVISORS PRIVATE LIMITED,NEW DELHI vs. NATIONAL E-ASSESSMENT CENTRE, DELHI, DELHI

In the result, the appeal of the Revenue is dismissed and appeal

ITA 854/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Jun 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2018-19 बनाम Deputy Commissioner Of Add Advisors Pvt. Ltd. Res-Cowork 03, 5Th Floor, Income Tax, Vs. Circle-1(1), Room No.153A, Caddie Commercial Tower, Aerocity, C.R. Building, I.P. Estate, Delhi International Airport, New Delhi. New Delhi. Pan No. Aaica3938N अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2018-19 बनाम Add Advisors Pvt. Ltd. Deputy Commissioner Of Res-Cowork 03, 5Th Floor, Vs. Income Tax, Caddie Commercial Tower, Aerocity, Circle-1(1), Room No.153A, Delhi International Airport, C.R. Building, I.P. Estate, New Delhi. New Delhi. Pan No. Aaica3938N अपीलाथ" Appellant ""यथ"/Respondent

Section 37(1)Section 69Section 69C

section 69C i.e. there must be an expenditure incurred and there should be failure of the assessee to explain the source of the expenditure to me satisfaction to the AO are not fulfilled, I believe the addition of Rs.3.75,0,000/- was not warranted. Accordingly, I direct the AO to delete the same. Ground no 3 is allowed

Showing 1–20 of 871 · Page 1 of 44

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34
Long Term Capital Gains23
Exemption18

GNP CONSULTANCY AND SOLUTIONS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 6 (1), MUMBAI, MUMBAI

Appeal of the revenue is dismissed

ITA 3430/MUM/2024[2022-23]Status: DisposedITAT Mumbai15 Jan 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

69C of the Act - Rs. 4,49,32,144/- (iii) Disallowance u/s. 37(1) - Rs. 15,75,000/- 4. The CIT(A) on further appeals gave partial relief to the assessee. Both the assessee and the Revenue are in appeal before the Tribunal Against the order of the CIT(A). The grounds raised by the Revenue and the assessee

ACIT CC 6(1), BKC MUMBAI vs. GNP CONSULTANCY AND SOLUTIONS PRIVATE LIMITED, THANE

Appeal of the revenue is dismissed

ITA 4480/MUM/2024[2018-19]Status: DisposedITAT Mumbai15 Jan 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

69C of the Act - Rs. 4,49,32,144/- (iii) Disallowance u/s. 37(1) - Rs. 15,75,000/- 4. The CIT(A) on further appeals gave partial relief to the assessee. Both the assessee and the Revenue are in appeal before the Tribunal Against the order of the CIT(A). The grounds raised by the Revenue and the assessee

ACIT CC 6(1), MUMBAI, BKC, MUMBAI vs. GNP CUNSULTANCY AND SOLUTIONS PVT. LTD., THANE

Appeal of the revenue is dismissed

ITA 4478/MUM/2024[2022-23]Status: DisposedITAT Mumbai15 Jan 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

69C of the Act - Rs. 4,49,32,144/- (iii) Disallowance u/s. 37(1) - Rs. 15,75,000/- 4. The CIT(A) on further appeals gave partial relief to the assessee. Both the assessee and the Revenue are in appeal before the Tribunal Against the order of the CIT(A). The grounds raised by the Revenue and the assessee

GNP CONSULTANCY AND SOLUTIONS PRIVATE LIMITED,NARIMAN POINT, MUMBAI vs. DCIT, CIRCLE 6(1), MUMBAI, MUMBAI

Appeal of the revenue is dismissed

ITA 3432/MUM/2024[2020-21]Status: DisposedITAT Mumbai15 Jan 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

69C of the Act - Rs. 4,49,32,144/- (iii) Disallowance u/s. 37(1) - Rs. 15,75,000/- 4. The CIT(A) on further appeals gave partial relief to the assessee. Both the assessee and the Revenue are in appeal before the Tribunal Against the order of the CIT(A). The grounds raised by the Revenue and the assessee

ACIT CC -6(1), MUMBAI, BKC, MUMBAI vs. GNP CONSULTANCY AND SOLUTIONS PVT. LTD., THANE

Appeal of the revenue is dismissed

ITA 4479/MUM/2024[2020-21]Status: DisposedITAT Mumbai15 Jan 2025AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishit Gandhi & AdnyaFor Respondent: Shri Kishor Dhula, CIT-DR & Shri
Section 132Section 132(4)Section 143(3)Section 37(1)Section 69C

69C of the Act - Rs. 4,49,32,144/- (iii) Disallowance u/s. 37(1) - Rs. 15,75,000/- 4. The CIT(A) on further appeals gave partial relief to the assessee. Both the assessee and the Revenue are in appeal before the Tribunal Against the order of the CIT(A). The grounds raised by the Revenue and the assessee

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

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 stated therein are satisfied before the said provisions are invoked. It is like laying a general rule

NETPLAST PVT.LTD.,KANPUR vs. ACIT CIRCLE 2(3)(1), KANPUR

In the result, the appeal of the assessee is partly allowed

ITA 320/LKW/2024[2017-18]Status: DisposedITAT Lucknow10 Jul 2025AY 2017-18
Section 133(6)Section 142(1)Section 14ASection 69C

69C of the I.T. Act, 1961 since you have failed to explain source of such entry and\nwhatever submission made by you are not satisfactory?\"\nIn response to above show cause, the assessee company furnished its reply on 22.11.2019. For the\nsake of convenience, reply furnished by the assessee is reproduced hereunder:-\n1. That we have purchased the land situated

L & T TECHNOLOGY SERVICES LIMITED,MUMBAI vs. ACIT CIRCLE 2(2)(1), MUMBAI

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 2542/MUM/2022[2018-19]Status: DisposedITAT Mumbai31 Oct 2023AY 2018-19

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blel & T Technology Services Limited V. Acit – Circle – 2(2)(1) L & T House, N.M. Marg Room No. 545, 5Th Floor Mumbai - 400001 Aaykar Bhavan, M.K. Road Mumbai - 400020 Pan: Aaccl4310P (Appellant) (Respondent) Assessee Represented By : Shri Nitesh Joshi Department Represented By : Shri Manoj Kumar

Section 144C(5)Section 14ASection 69CSection 90

TRANSFER PRICING ISSUES 2. The Assessing Officer erred in adding the premia income on forward contracts to the total income of the Appellant without appreciating the fact that the premia income had already been offered to tax in the earlier years. 3. Without prejudice to Ground No.2, the Assessing Officer erred in adding an amount of Rs.49

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

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 stated therein are satisfied before the said provisions are invoked. It is like laying a general rule

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

69C or section 69D, if such income is not covered under clause (a), the income-tax payable shall be the aggregate of- (i) the amount of income-tax calculated on the income referred to in clause (a) and clause (b), at the rate of sixty per cent.; and (ii) the amount of income-tax with which the assessee would have

EXECUTIVE TRADING CO. PVT LTD.,AHMEDABAD vs. COMM OF INCOME TAX (A), NFAC, DELHI, DELHI

ITA 281/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Jul 2023AY 2017-18
For Appellant: Shri Vijay MehtaFor Respondent: Shri Biswanath Das
Section 142(1)Section 144BSection 147Section 148Section 69C

69C of the Act chargeable to tax at the rate of 60% in terms of Section 115BBE of the Act. Being aggrieved, the Appellant preferred appeal before the CIT(A) 5. challenging the Assessment Order, dated 29/09/2021, passed under Section 147 read with Section 144B of the Act on the ground of lack of jurisdiction to initiate reassessment proceedings

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 140/NAG/2021[2018-19]Status: DisposedITAT Nagpur29 Jul 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA MADHAV DEVELOPER , NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 47/NAG/2021[2011-12]Status: DisposedITAT Nagpur29 Jul 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ASSTT.COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1), NAGPUR vs. M/S RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 27/NAG/2020[2015-16]Status: DisposedITAT Nagpur29 Jul 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ASSTT.COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1), NAGPUR vs. M/S RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 26/NAG/2020[2014-15]Status: DisposedITAT Nagpur29 Jul 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR vs. M/S. RADHA RADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 49/NAG/2021[2013-14]Status: DisposedITAT Nagpur29 Jul 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1),NAGPUR, NAGPUR vs. M/S. RADHA MADHAV DEVELOPER, NAGPUR

In the result, all the six appeals preferred by the department are dismissed

ITA 48/NAG/2021[2012-13]Status: DisposedITAT Nagpur29 Jul 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

Section 142ASection 145

transfer price audit report and other relevant evidence also. Further, after delivery, there is an unexplained expenditure in the hands of the appellant. This must be to suppress the turnover in the hands of Sufalam Infra Projects Pvt. Ltd. Sufalam Infra Projects Pvt. Ltd., was also subject to search proceeding u/s 132 of the IT Act, 1961 and assessment orders

ACIT(E), LUCKNOW vs. M/S. BHAGWANT INSTITUTE OF TECHNOLOGY, BIJNOR

In the result, the appeal of the Revenue is partly allowed

ITA 219/LKW/2020[2013-14]Status: DisposedITAT Lucknow31 Oct 2025AY 2013-14
For Appellant: \nShri R. K. Agarwal CIT(DR)For Respondent: \nShri Vinod Kumar, CA
Section 11Section 143(2)

price fixation' is neither the forte nor the function\nof the Court and it cannot be contended that education must be available\nfree and it must be run on a charitable basis. Apex court ruled that the\ntime is not yet ripe to hold that education must be made available on a\ncharitable basis and it is true whenever trusts

MILESTONE DEWELLERS PVT. LTD.,JAIPUR vs. ITO WARD 6(2), JAIPUR

In the result, appeal of the assessee is allowed

ITA 565/JPR/2023[2017-18]Status: DisposedITAT Jaipur31 Oct 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 143(3)Section 144BSection 147

transferring proportionate cost of units sold during FY 2013-14 to 2016-17 to the profit & loss account whereas the DVO has estimated the fair cost of entire residential project including the sold units. Hence, the appellant's submission on this count is prima facie correct. 4.1.8 The appellant submitted that the DVO has not granted rebate for self- supervision