ACIT, BANGALORE vs. M/S BOSCH LIMITED, BANGALORE

ITA 695/BANG/2011Status: DisposedITAT Bangalore20 August 2015AY 2004-0516 pages
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What did the Tribunal hold?

The Tribunal held that the assessee failed to substantiate its claim for deduction under Section 80-O due to lack of cogent evidence. However, the revenue's appeal regarding the exclusion of design and development fees from business profits for Section 80HHC calculation was dismissed.

What were the facts?

The assessee, Bosch Ltd., appealed against transfer pricing adjustments and the disallowance of deduction under Section 80-O. The revenue also appealed against the CIT(A)'s order allowing certain deductions.

What were the issues?

Whether transfer pricing adjustments were justified and if the assessee was eligible for deduction under Section 80-O. Also, whether certain fees should be excluded from business profits for Section 80HHC calculation.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 80-O,Section 80HHC

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Income Tax Appellate Tribunal, ‘A’ BENCH : BANGALORE

Before: SMT. P. MADHAVI DEVI & SHRI ABRAHAM P GEORGE

For Appellant: Shri Percy Pardiwala, Sr. Counsel

Per Smt. P.MADHAVI DEVI, JM:

These are cross appeals both by the assessee as well as the revenue against the order of the CIT(A) LTU, Bangalore, dated 28/03/2011 for the assessment year 2004-05. ITA Nos.670 & 695/Bang/2011 M/s.Bosch Ltd. IT(TP)A No.670/Bang/2011 (Assessee’s appeal): 2. The assessee has raised as many as 10 ground of appeal out of which ground of appeal Nos.1 and 10 are general in nature and need no adjudication.

3.

Ground No.2 to 7 are against the transfer pricing (TP) adjustment made by the Transfer Pricing Officer (TPO) u/s 92CA of the Income-tax Act, 1961 [ ‘the A

The order continues below.

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