535 (Bang) and Brigade Global Services Pvt. Ltd. v. ITO

143 ITD 59Income Tax Appellate Tribunal2013#22554 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 348,356 Indian tax judgments — from 2023 to 2025.

Judgments citing 535 (Bang) and Brigade Global Services Pvt. Ltd. v. ITO

Swatch Group (India) Retail Private Limited, Delhi vs. The Deputy Commissioner of Income Tax, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 4281/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Royswatch Group (India) Retail Private Ltd., Vs. Dcit, Circle 22(2), 4Th Floor, Rectangle 1, Plot No.D4, Delhi. Saket District Centre, Saket, New Delhi – 110 017. (Pan : Aavcs7960H) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 16.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 26.07.2024 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)Section 92D

…n)  Birla Soft (India) Limited Vs. DCIT [(2011) 44 SOT 664 (Delhi)](refer page 53-69 of the Case Law Compilation)  Aramex India (P.) Ltd. vs. DCIT (ITA 6749/Mum/2017)(refer page 70-89 of the Case Law Compilation)  Brigade Global Services (P.) Ltd. vs. ITO (143 ITD 59) (Hyd)(refer page 90-110 of the Case Law Compilation)  DCIT v. M/s. Parled Technologies Ltd. (formerly Four Soft Ltd.), 2017 (11) TMI 1832(refer page 111-119 of the Case Law Compilation) 15.14. Thus, rejection of segmental financial information which has been specifically drawn for determination of arm’s length price merely because it has not bee…

Datamatics Global Services Ltd, Mumbai vs. DCIT 9(3)(1), Mumbai

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

ITA 2260/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 Mar 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Datamatics Global Services Ltd. Dy. Cit-9(3)(1) Plot No. 58, Street No. 17, Mumbai Midc, Andheri (E), Vs. Mumbai – 400 093

For Appellant: Shri Harsh Shah/Pratik Poddar/For Respondent: Dr. Samuel Pitta

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

…lis Processing Services (India) Limited (supra) for this proposition and has also relied on 9 Datamatics Global Services Ltd. vs. Dy. CIT Goldman Sachs Services Pvt. Ltd. [2020] 117 taxmann.com 535 (Bang) and Brigade Global Services Pvt. Ltd. vs. ITO [2013] 143 ITD 59 (Hyd.) The assessee has also relied on the decision of Baxter India Pvt. Ltd. (supra) which held that as the company has not allocated employee cost to infrastructure activity segment, the same was said to be highly impractical as 49% of its total revenue was from its infrastructure activities. It was held in Motorola Solutions Pvt. Ltd. [2014]…

Dic India Ltd., Kolkata vs. DCIT, Circle - 10(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2084/KOL/2018[2014-15]Status: DisposedITAT Kolkata04 Jan 2023AY 2014-15

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No. 2084/Kol/2018 Assessment Year: 2014-2015 Dic India Limited,..................................Appellant Transport Depot Road, Kolkata-700088 [Pan: Aabcc0703C] -Vs.- Deputy Commissioner Of Income Tax,......Respondent Circle-10(1), Aayakarbhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Akkaldudhwewala, A.R., Appeared On Behalf Of The Assessee Shri Hukumasema, Cit, Appeared On Behalf Of The Revenue

Section 144CSection 144C(5)

…that although there is no legal M/s. Syniverse Mobile Solutions Private Limited, Hyderabad requirement to get the segmental financials audited, it is always preferable for establishing the reliability." (ii) Brigade Global Service Pvt. Ltd. Vs ITO, Hyderabad [143 ITD 59], wherein it was observed as follows: "The AR submitted that, in respect of F.I. Sofex (item No. 11 in the chart) introduced by the assessee but rejected by Learned CIT (Appeals) as well as TPO on the ground that nosegmental details were available. Whereas the fact remains that the assessee had furnished the segmental data. The Mumbai Tribunal in…