How many judgments cite 2417 Customer (P.) Ltd. v. Dy. CIT?

22 judgments on BharatTax cite 2417 Customer (P.) Ltd. v. Dy. CIT (140 ITD 344), spanning 2015 to 2021.

2417 Customer (P.) Ltd. v. Dy. CIT

140 ITD 344Income Tax Appellate Tribunal2013#5198 most cited

What is 2417 Customer (P.) Ltd. v. Dy. CIT authority for?

Companies with related party transactions (RPT) up to 15% of total revenues can be considered comparable in transfer pricing analysis, especially when there is a lack of other comparables.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2021.

Also referred to as

2417 Customer (P.) Ltd. v. Dy. CIT · ITAT · transfer pricing · comparable companies · RPT · related party transactions · 15% revenue threshold

Judgments citing 2417 Customer (P.) Ltd. v. Dy. CIT

M/S CENTUM RAKON INDIA PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed

ITA 1964/BANG/2017[2009-10]Status: DisposedITAT Bangalore01 Nov 2021AY 2009-10

Bench: Shri Chandra Poojari & Smt Beena Pillaiita. No. 1964/Bang/2017 Assessment Year: 2009-10 M/S. Rakon India Pvt. The Deputy Ltd., Commissioner Of #12, Khb Industrial Area, Income Tax, Yelahanka New Town, Circle 2(1)(1), Bangalore – 560 106. Vs. Bangalore. Pan: Aadcc2533L (Appellant) (Respondent) Appellant By : Shri Sandeep Chalapathy, Ca Shri Kannan Narayanan, Jcit Respondent By : (Dr) Date Of Hearing : 17.08.2021 Date Of Pronouncement : 01.11.2021 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 14/07/2017 Passed By The Ld.Cit(A), Bangalore-2 For Assessment Year 2009-10 On Following Grounds Of Appeal: “1. That The Order Of The Learned Commissioner Of Income Tax (Appeals) In So Far It Is Prejudicial To The Interests Of The Appellant Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. 2. That The Learned Commissioner Of Income Tax (Appeals) Erred In Law & On Facts In Determining The Alp Of International Transaction At Rs. 32,77,99,833 /- 3. Comparables: 3.1. That The Learned Commissioner Of Income Tax (Appeals) Erred In Law & On Facts In Choosing M/S. Valiant Communication Ltd As A Comparable Entity Ignoring The Fact That M/S. Valiant Communication

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: (DR)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “A” BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER ITA. No. 1964/Bang/2017 Assessment Year: 2009-10 M/s. Rakon India Pvt. The Deputy Ltd., Commissioner of #12, KHB Industrial Area, Income Tax, Yelahanka New Town, Circle 2(1)(1), Bangalore – 560 106. vs. Bangalore. PAN: AADCC2533L (Appellant) (Respondent) Appellant by : Shri Sandeep Chalapathy, CA Shri Kannan Narayanan, JCIT Respondent by : (DR) Date of Hearing : 17.08.2021 Date of Pronouncement : 01.11.2021 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Presen…

DCIT, BANGALORE vs. M/S CISCO SYSTEMS BV - INDIA BRANCH, BANGALORE

In the result appeal filed by revenue stands partly allowed and appeal filed by assessee stands allowed

ITA 309/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Aug 2021AY 2011-12

Bench: Shri Br Baskaran & Smt. Beena Pillaiit(It)A No.309/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Rajan Vora, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 1O

…ompanies even in a case where there are single and insignificant RPT was not correct. The learned counsel for the Assessee, on the other hand, pointed out that this Tribunal, in the eases of 2417 Customer (P.) Ltd. v. Dy. CIT [2012] 28 taxrnann.com 258/[2013] 140 ITD 344 (Punj.)Sony India (F) Ltd. v. Dy. CIT [2008] 114 LTD 448 (Delhi) and various other cases, has taken a view that comparables having RPT of upto 15% of total revenues can be considered as comparable company. We have considered the rival submission. It is no doubt true that in the case of Robert Bosch (supra) this Tribunal has held that RPT filter c…

DEPUTY COMMISSIONER OF INCOME TAX -14(1)(2), MUMBAI vs. CITICORP SERVICES INDIA LIMITED , MUMBAI

In the result, appeal of the Revenue is partly allowed and appeal of the assessee is dismissed

ITA 4609/MUM/2017[2010-11]Status: DisposedITAT Mumbai20 Jul 2021AY 2010-11

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K‘ BENCH MUMBAI BEFORE: SHRI SAKTIJIT DEY, JUDICIAL MEMBER & SHRI M.BALAGANESH, ACCOUNTANT MEMBER The Dy. Commissioner of Vs. M/s. Citicorp Services India Income Tax-14(1)(2) Ltd., Room No. 470, 4th Floor Citibank Centre, Aayakar Bhavan Plot No.C-61, Bandra Kurla Maharshi Karve Road Complex, Bandra East Mumbai – 400 020 Mumbai – 400 051 PAN/GIR No.AADCC6705C (Appellant) .. (Respondent) M/s. Citicorp Services Vs. The Dy. Commissioner of India Ltd., Income Tax-14(1)(2) Room No. 470, 4th Floor First International 8th Financial Centre, Aayakar Bhavan Floor, Plot Nos. C-54 Mah…

24/7 CUSTOMER PRIVATE LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeal by the assessee and revenue are treated as partly allowed, while CO of the assessee is partly allowed for statistical purposes

ITA 550/BANG/2015[2010-11]Status: DisposedITAT Bangalore20 Sept 2019AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Vikram Singh Yadav, Accountant Membe It(Tp)A No.498/Bang/2015 Assessment Year : 2010-11

For Appellant: NoneFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR), ITAT, Bangalore

Section 143(3)Section 92C

…ompanies even in a case where there are single and insignificant RPT was not correct. The learned counsel for the Assessee, on the other hand, pointed out that this Tribunal, in the eases of 2417 Customer (P.) Ltd. v. Dy. CIT [2012] 28 taxrnann.com 258/[2013] 140 ITD 344 (Punj.) Sony India (F) Ltd. v. Dy. CIT [2008]114 LTD 448 (Delhi) and various other cases, has taken a view that comparables having RPT of upto 15% of total revenues can be considered as comparable company. We have considered the rival submission. It is no doubt true that in the case of Robert Bosch (supra) this Tribunal has held that RPT filter c…

ASST.C.I.T., BANGALORE vs. M/S 24/7 CUSTOMER PVT. LTD.,, BANGALORE

In the result, the appeal by the assessee and revenue are treated as partly allowed, while CO of the assessee is partly allowed for statistical purposes

ITA 498/BANG/2015[2010-11]Status: DisposedITAT Bangalore20 Sept 2019AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Vikram Singh Yadav, Accountant Membe It(Tp)A No.498/Bang/2015 Assessment Year : 2010-11

For Appellant: NoneFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR), ITAT, Bangalore

Section 143(3)Section 92C

…ompanies even in a case where there are single and insignificant RPT was not correct. The learned counsel for the Assessee, on the other hand, pointed out that this Tribunal, in the eases of 2417 Customer (P.) Ltd. v. Dy. CIT [2012] 28 taxrnann.com 258/[2013] 140 ITD 344 (Punj.) Sony India (F) Ltd. v. Dy. CIT [2008]114 LTD 448 (Delhi) and various other cases, has taken a view that comparables having RPT of upto 15% of total revenues can be considered as comparable company. We have considered the rival submission. It is no doubt true that in the case of Robert Bosch (supra) this Tribunal has held that RPT filter c…

M/S RITTAL INDIA PVT LTD ,DODDABALLAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , BANGALORE

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 2494/BANG/2017[2013-14]Status: DisposedITAT Bangalore17 May 2019AY 2013-14

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri S Ramasubramanyam, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR) by

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH : BANGALORE BEFORE SHRI B.R BASKARAN, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER IT(TP)A No.2494/Bang/2017 Assessment year : 2013-14 M/s Rittal India Pvt. Ltd., Vs. The Dy. Commissioner of Income- No.23 & 24, tax, Circle-1, LTU, KIADB Industrial Area, Veerapura, Bangalore. Doddaballapur-561 203. PAN – AAACB 7927 A APPELLANT RESPONDENT Appellant by : Shri S Ramasubramanyam, C.A Respondent : Shri Pradeep Kumar, CIT (DR) by Date of hearing : 25.02.2019 Date of Pronouncement : 17.05.2019 O R D E R PER SHRI B.R BASKARAN, ACCOUNTANT MEMBER Th…

M/S SNECMA HAL AEROSPACE PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 432/BANG/2015[2010-11]Status: DisposedITAT Bangalore17 May 2019AY 2010-11

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri C.H Sundar Rao, CIT

Section 1Section 143(3)Section 92C(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH : BANGALORE BEFORE SHRI B.R BASKARAN, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER IT(TP)A No.432/Bang/2015 Assessment year : 2010-11 M/s Snecma HAL Aerospace Pvt. Ltd., Vs. The Income-tax Officer, No.140/1, Hoody Whitefield, Ward-6(1)(3), Bangalore-560 066. Bangalore. PAN – AAJCS 4358 M APPELLANT RESPONDENT Assessee by : Shri Vishal Kalra, Advocate Revenue by : Shri C.H Sundar Rao, CIT Date of hearing : 21.03.2019 Date of Pronouncement : 17.05.2019 O R D E R Per B.R Baskaran, Accountant Member The assessee has filed this appeal challengi…

M/S. EATON TECHNOLOGIES PRIVATE LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

Appeal of the assessee is partly allowed for statistical purposes

ITA 400/PUN/2014[2009-10]Status: HeardITAT Pune06 Mar 2019AY 2009-10

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Vishal Kalra

Section 92C(1)Section 92C(2)

…of its work could not be construed to be a good comparable with an assessee who was carrying out the work by itself. To the similar effect is also the decision of the Bangalore Bench of the Tribunal in the case of 2417 Customer.Com (P) Ltd. v. Dy. CIT [2013] 140 ITD 344/[2012] 28 taxmann.com 258.The decision of the Pune Bench of the Tribunal in the case of PTC Software (India) (P) Ltd. (supra) is also to the similar effect. Therefore, in our considered opinion, having regard to the difference in the business model brought out by the assessee, M/s. Cosmic Global Services Ltd. is liable to the excluded from the fi…

M/S SUNQUEST INFORMATION SYSTEMS (INDIA) PRVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 552/BANG/2015[2010-11]Status: DisposedITAT Bangalore21 Dec 2018AY 2010-11

Bench: Shri N.V Vasudevanshri Jason P Boazit(Tp)A No.552/Bang/2015

For Respondent: Shri C.H Sundar Rao, CIT

Section 143(3)Section 40Section 92

…ompanies even in a case where there are single and insignificant RPT was not correct. The learned counsel for the Assessee, on the other hand, pointed out that this Tribunal, in the eases of 2417 Customer (P.) Ltd. v. Dy. CIT [2012] 28 taxrnann.com 258/[2013] 140 ITD 344 (Punj.) Sony India (F) Ltd. v. Dv. CIT [2008]114 LTD 448 (Delhi) and various other cases, has taken a view that comparables having RPT of upto 15% of total revenues can be considered as comparable IT(TP)A No.552/B/15 10 company. We have considered the rival submission. It is no doubt true that in the case of Robert Bosch (supra) this Tribunal…

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1372/KOL/2017[2009-10]Status: DisposedITAT Kolkata19 Sept 2018AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

…ered by various courts in the country which have considered such RPT (related party transaction) limit at 15 % to 25% and these judgments are as follows: a) DCIT vs. Synopsis India (P) Ltd. (2015) 64 taxmann.com 10 (Bang) b) 24/7 customer.com v. DCIT (2013) 140 ITD 344 (Bang) c) Cordys R & D India (P) Ltd. (2014) 149 ITD 587 (Hyd) d) SAP (India) Pvt. Ltd. v. Addl. CIT(2012) 87 taxmann.com 316 (Bangalore AT) Page 42 of case law paper book) [RPT tolerance unit between 15% to 25%] Hence it may be held accordingly. The ld Counsel objected the seven comparable selected by the ld TPO. The ld TPO selected the seve…

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1371/KOL/2017[2008-09]Status: DisposedITAT Kolkata19 Sept 2018AY 2008-09

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

M/S. OKS SPAN TECH PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee stands partly allowed in terms of our observations and findings in the

ITA 1551/DEL/2015[2010-11]Status: DisposedITAT Delhi23 Aug 2018AY 2010-11

Bench: Shri Pramod Kumar & Shri Sudhanshu Srivastava

Section 14ASection 92C

…ts customers and, therefore, it was not comparable with a company providing ITES services having no intangibles of its own. The ITAT Delhi Bench followed the order of ITAT Bangalore Bench in the case of 24/7 customer.com(P.) Ltd. vs. DCIT reported in (2013) 140 ITD 344 Bangalore while directing the exclusion of this company wherein it was noted that Fortune Infotec had developed its own software called ‘Finetran’ and ‘Image Index’ for performing specialized services in medical transcription and patient record management. Accordingly, in view of the funcational dissimilarity as noted by the coordinate benches…

PR COMMISSIONER OF vs. M/S SYNOPSYS INDIA P LTD.,

ITA/280/2016HC Karnataka01 Aug 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260Section 260A

…y, the learned Tribunal has considered and excluded the other comparables also. 5. The appeal ITA No.141/2013 filed by the appellants-Revenue challenging the decision followed by the Tribunal in the case of 24/7 Customer.com Pvt. Ltd. vs. DCIT (2013) 140 ITD 344 has been dismissed by this Court on 10.07.2018 holding that no substantial question of law arises for consideration placing reliance on the recent judgment of this Court passed in ITA No.536/2015 C/w ITA No.537/2015 delivered on 25.06.2018 Date of Judgment 01-08-2018 I.T.A.No.280/2016 Pr. Commissioner o…

SWISS RE SHARED SERVICES (INDIA) PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal is allowed and the Revenue’s

ITA 1139/BANG/2011[2004-05]Status: DisposedITAT Bangalore03 May 2017AY 2004-05

Bench: Shri. Vijay Pal Rao & Shri. S. Jayaraman

For Appellant: Shri. Sampath Raghunathan, AdvocateFor Respondent: Shri. M. K. Biju, JCIT

Section 10A

…dia Private Ltd , Wipro BPO Solutions Ltd, Fortune IT(TP)A.1139 & 1205/Bang/2011 Page - 9 Infotech Ltd and Vishal Information Technology Ltd, he relied on this Tribunal decision in the case of 24/7 Customer.Com P Ltd v DCIT , Circle 11(2), Bangalore [2013] 140 ITD 344 (ITAT[Bang]) of assessment year 2004-05 in IT A No. 227 (Bang) of 2010 , which was engaged in the business of call centre services exclusively to its AEs. On rejection of Ultramarine & Pigments Ltd, the AR relied on the Hyderabad Tribunal decision in the case of Brigade Global Services P Ltd v ITO [2013] 33 taxmann.com 618 (Hyd) which was enga…

SCANCAFE DIGITAL SOLUTIONS PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

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

ITA 502/BANG/2015[2010-11]Status: DisposedITAT Bangalore12 Apr 2017AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Laliet Kumar

For Appellant: Shri Chavali Narayan, CAFor Respondent: Shri G.Kamaladhar, Standing Counsel

Section 143(3)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: BENGALURU BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER and SHRI LALIET KUMAR, JUDICIAL MEMBER IT(TP)A No.502/Bang/2015 (Assessment year: 2010-11) and Cross Objn.No.139/Bang/2015 (In IT(TP)A No.502/Bang/2015) (Assessment year: 2010-11) M/s.Scancafe Digital Solutions Pvt. Ltd. Ground Floor, Neil Rao Towers, Plot No.118, Road No.03, EPIP Phase-1, Whitefield Main Road, Bengaluru-560066 … Appellant PAN:AAKCS 5398 E Vs. Income-tax Officer, Ward 6(1)(1), Bengaluru. … Respondent AND IT(TP)A No.450/Bang/2015 (Assessment year: 2010-11) (By the Revenue) Assessee by : S…

ACUSIS SOFTWARE INDIA PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeal filed by the assessee in IT(TP)A No

ITA 442/BANG/2011[2004-05]Status: DisposedITAT Bangalore04 Nov 2016AY 2004-05

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri. Chavali Narayana, CAFor Respondent: Shri. D. Sudhakar Rao, CIT-DR

Section 143(2)Section 92C

…. If it is demonstrated with some evidence that the abnormal losses/profits are incurred on account of some special reasons, the same may be excluded. The coordinate bench in the case of 24/7 Customer.com (P.) Ltd. Vs. Dy. CIT [2012] 28 taxmann.com 258/[2013] 140 ITD 344 (Bang. – Trib.) following the decision of Exxon Mobil Company India (P.) Ltd. Vs. Dy. CIT [2011] 12 taxmann.com 84/46 SOT 294 (URO) (Mum.-Trib), held to the same effect. We find from the record that the TPO/AO had not undertaken the exercise of going into the reasons for abnormal losses. Therefore we remit back to the file of TPO/AO to undertake…

NOVELL SOFTWARE DEVELOPMENT (INDIA) PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result grounds 4.a, 4

ITA 1287/BANG/2011[2007-08]Status: DisposedITAT Bangalore31 Mar 2016AY 2007-08

Bench: Shri. Abraham P. George & Shri. Vijay Pal Raoi.T(Tp).A No.1287/Bang/2011 (Assessment Year : 2007-08) Novell Software Development (India) P. Ltd, Bagmane Tech Park, ‘D’ Block, 65/2, C. V. Raman Nagar, Byrasandra Post, Bangalore 560 093 .. Appellant Pan : Aaacn6992K V. Deputy Commissioner Of Income-Tax, Circle -12(2), Bangalore .. Respondent Assessee By : Shri. T. Suryanarayana, Advocate Revenue By : Shri. G. R. Reddy, Cit –Dr-I Heard On : 21.03.2016 Pronounced On : 31.03.2016 O R D E R Per Abraham P. George:

For Appellant: Shri. T. Suryanarayana, AdvocateFor Respondent: Shri. G. R. Reddy, CIT –DR-I

Section 144C

…sidered as a good precedent for excluding the above mentioned companies. As for Geometric Ltd (seg), Ld. AR submitted that RPT of the said company exceeded 15% and by virtue of coordinate bench decision in the case of 24/7 customer.com Pvt Ltd v. DCIT [(2013) 140 ITD 344] had to be excluded. Vis a vis Quintegra Solutions Ltd, Ld. AR submitted that comparability of the said company in software development services was an issue which had come up before this Tribunal in the case of NXP Semiconductors India P. Ltd, [IT(TP)A.1174/Bang/2011, dt.14.11.2014]. As per the Ld. AR, it was held in the said decision that Quint…

DCIT, BANGALORE vs. M/S TELELOGIC INDIA PRIVATE LIMITED, BANGALORE

In the result, the revenue’s appeal is partly allowed

ITA 30/BANG/2012[2005-06]Status: DisposedITAT Bangalore16 Mar 2016AY 2005-06

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri G.R. Reddy, CIT(DR)

Section 143(3)Section 250Section 92CSection 92C(2)

…not exceeding 15% can be taken as a comparable. This ratio was followed by IT(TP)A No.22 & 30/B/2012 Page 19 of 21 the Coordinate Benches of the Tribunal in the following decisions: i. Customer.Com Pvt. Ltd. Vs. DCIT, [2012] 28 taxmann.com 258 (Bang.): [2013] 140 ITD 344 (Bang.) : [2013] 21 ITR (Trib.) 514 (Bang.) ii. ITO Vs. CRM Services India (P.) Ltd. [2011] 14 taxmann.com 96 (Del): [2011] 48 SOT 41 (Del) (URO). iii. CSR India (P) Ltd. Vs. ITO [2013] 31 taxmann.com 265 (Bang.) iv. Logica Pvt. Ltd. Vs. ACIT, IT(TP)A No. 1129/Bang/2011: TS-131-ITAT-2013-BANG-TP. Avaya India (P.) Ltd. Vs ACIT [2013] 33 taxmann.co…

M/S. VERISIGN SERVICES INDIA PVT. LTD.,BANGALORE vs. DCIT, BANGALORE

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

ITA 1404/BANG/2010[2006-07]Status: DisposedITAT Bangalore30 Oct 2015AY 2006-07

Bench: Smt Asha Vijayaraghavan & Shri Abraham P George

For Appellant: Shri Pravin Kishore Prasad, AdvocateFor Respondent: Shri I.P.S.Bindra, CIT-DR-I

Section 143(3)Section 92C(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH ‘A’, BANGALORE BEFORE SMT ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER AND SHRI ABRAHAM P GEORGE, ACCOUNTANT MEMBER IT(TP)A No.1404(B)/2010 (Assessment year : 2006-07) M/s VeriSign Services India Pvt.Ltd., Summit No.6/B, 7th Main, 3rd Block, 80 Feet Road, Koramangala, Bangalore 560-034 Appellant PAN No.AAACL8712F Vs The Deputy Commissioner of Income-tax, Circle-12(5), 14/3, 5th Floor, R.P.Bhavan, Nrupathunga Road, Bangalore-560 001 Respondent Assessee by : Shri Pravin Kishore Prasad, Advocate Revenue by : Shri I.P.S.Bindra, CIT-DR-I Date of hearing : 14-10-2015…

DCIT, BANGALORE vs. SYNOPSIS INDIA PVT. LTD.,, BANGALORE

ITA 1107/BANG/2011[2005-06]Status: DisposedITAT Bangalore08 Oct 2015AY 2005-06

Bench: Smt. Asha Vijayaraghavan & Shri. Abraham P. Georgei.T(Tp).A No.1107/Bang/2011 (Assessment Year : 2005-06) Deputy Commissioner Of Income-Tax, Circle – 12 (3), Bangalore ..Appellant V. Synopsis India P. Ltd, Rmz Infinity Tower Á’, 4Th & 5Th Floor, No.3, Old Madras Road, Benniganahalli, Bangalore 560016 ..Respondent Pan : Aabcs8847D I.T(Tp).A No.1093/Bang/2011 (Assessment Year : 2005-06) (By The Assessee) Assessee By : Shri. Dhanesh Bafna, Ca Revenue By : Shri. Farhat Hussain Qureshi, Cit -Dr Heard On : 08.09.2015 Pronounced On : 08.10.2015 O R D E R Per Abraham P. George:

For Appellant: Shri. Dhanesh Bafna, CAFor Respondent: Shri. Farhat Hussain Qureshi, CIT -DR

Section 10A

…% of the RPT directed by the CIT (A) went against various decisions of the Tribunal. Specific reliance was placed on the IT(TP)A.1107 & 1093/Bang/2011 Page - 3 decision of Bangalore Bench of the Tribunal in the case of 24/7 customer.com Pvt Ltd vs DCIT (2013) 140 ITD 344. 07. Per contra, Ld. AR submitted that though he was not having any objection for adopting the 15% RPT filter, as held in the case of 24/7 Customer.Com P. Ltd (supra), the RPT worked out for Geometric software Ltd, by the lower authorities at 11.49% was incorrect. According to him, Geometric Software Solutions Co., had RPT of 24.1%. He placed rel…

Showing 1–20 of 22 · Page 1 of 2