ACIT-CIRCLE-4(1)(1), BANGALORE vs. EYGBS(INDIA) PRIVATE LIMITED, BANGALORE

ITA 1886/BANG/2024Status: DisposedITAT Bangalore21 September 2026AY 2012-1322 pages
AI SummaryDismissed

What were the facts?

The assessee claimed deduction under Section 10AA on income from SEZ unit, including voluntary transfer pricing adjustments. The Assessing Officer (AO) made several disallowances, including under Section 14A and denied deduction under Section 10AA on voluntary TP adjustment. The CIT(A) set aside the AO's order.

What did the Tribunal hold?

The Tribunal held that the CIT(A) correctly followed precedents and the jurisdictional High Court's judgment in excluding comparables. The Tribunal found no reason to interfere with the CIT(A)'s order which was based on facts and earlier Tribunal orders.

What were the issues?

Whether the CIT(A) erred in excluding comparables for transfer pricing adjustment and allowing deduction under Section 10AA on voluntary TP adjustment, considering pending appeals and Tribunal orders.

Which sections of the Income-tax Act were involved?

Section 10AA,Section 14A,Section 92CA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SOUNDARARAJAN K.

For Respondent: Shri Chavali Narayan, CA

PER SHRI SOUNDARARAJAN K., JUDICIAL MEMBER:

This is an appeal filed by the revenue challenging the order of the Ld.CIT(A) – 12, Bengaluru dated 14/06/2024 in respect of the A.Y. 2012-13. 1 M/s. EYGBS (India) Pvt. Ltd.

2.

The brief facts of the case are that the assessee is a private limited company and a subsidiary of EYGI B.V., Netherlands. The assessee is engaged in the busines

The order continues below.

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