Societe Generale Global Solution Centre Private Limited, Bangalore vs. Deputy Commissioner of Income Tax
In the result, the assessee’s appeal is partly allowed for statistical purposes
ITA 2297/BANG/2016[2012-13]Status: DisposedITAT Bangalore22 Feb 2019AY 2012-13
Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleit(Tp)A No.2297/Bang/2016 (Assessment Year: 2012-13) M/S. Societe Generale Global Solution Global Centre Pvt. Ltd., 10Th Floor, ‘Voyager’ Building, Itpl, Whitefield, Bengaluru-560 066. Pan:Aaecs 6764 L … Appellant Vs. Deputy Commissioner Of Income-Tax, Circle 6(1)(2), Bengaluru. … Respondent Appellant By : Shri Sampath Raghunathan, Advocate Respondent By : Shri Pradeep Kumar, Cit(Dr) Date Of Hearing: 14/02/2019 Date Of Pronouncement: 22/02/2019 O R D E R Per Pavan Kumar Gadale, Jm : The Assessee Has Filed The Appeal Against The Order Of The Deputy Commissioner Of Income-Tax, Circle 6(1)(2), Bengaluru, U/S 143(3) R.W.S. 144C(13) Of The Income-Tax Act,1961 ['The Act' For Short] Dated 28/10/2016, Passed In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) Dated 31/08/2016. It(Tp)A No.2297/Bang/2016 Page 2 Of 20 2. The Assessee Has Filed Grounds Of Appeal With Appeal Memo & Raised Additional Grounds Of Appeal Before The Tribunal. At The Time Of Hearing, The Learned Ar Has Not Pressed Grounds In Respect Of Ground No.1 Which Are General In Nature & Whereas In Respect Of Ground No.2 On Determination Of Arm’S Length Price (Alp) Of International Transaction , Learned Ar Has Not Pressed Grounds No.2(A), 2(B), 2(E), 2(F), 2(G), 2(H), 2(I), 2(J), 2(K), 2(L), 2(M) & 2(N) & Ground No.3, Non-Cognizance To Rectification Application Filed Before The Tpo Not Pressed & Ground No.4, Non-Allowance Of Appropriate Adjustments To The Comparable Companies Being 4(A)And 4(B) Not Pressed Ground No.8, Directions Issued By The Drp, Ground No.9 Penalty Proceedings & Ground No.10 Are Also Not Pressed. Hence, The Effective Grounds Of Appeal Are Ground Nos.2(C), 2(D), 5, 6 & 7. Which Read As Under:
For Appellant: Shri Sampath Raghunathan, AdvocateFor Respondent: Shri Pradeep Kumar, CIT(DR)
Section 115JSection 143(3)Section 92C(2)
…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BENGALURU BEFORE SHRI A.K. GARODIA, ACCOUNTANT MEMBER and SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER IT(TP)A No.2297/Bang/2016 (Assessment year: 2012-13) M/s. Societe Generale Global Solution Global Centre Pvt. Ltd., 10th Floor, ‘Voyager’ Building, ITPL, Whitefield, Bengaluru-560 066. PAN:AAECS 6764 L … Appellant Vs. Deputy Commissioner of Income-tax, Circle 6(1)(2), Bengaluru. … Respondent Appellant by : Shri Sampath Raghunathan, Advocate Respondent by : Shri Pradeep Kumar, CIT(DR) Date of hearing: 14/02/2019 Date of pronouncement: 22/02/2019 O R D E R Per PAVAN KU…
