Equant Solutions India (P.) Ltd. v. Dy. CIT

157 ITD 292Income Tax Appellate Tribunal2016#10460 most cited
10

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2026.

Also reported as

66 Taxmann.com 2

Sections most often in play

Section 10(B)(2)Section 12(4)Section 250Section 250 of the Income Tax ActSection 40(a)(i)Section 40(a)(i) of the Income Tax ActSection 9(1)(vii)Section 9(1)(vii) of the Income Tax Act

Judgments citing Equant Solutions India (P.) Ltd. v. Dy. CIT

ACIT, CIRCLE-1(1)(1), BANGALORE vs. AMAZON DEVELOPEMENT CENTRE(INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeal of the revenue for A

ITA 2127/BANG/2024[2012-13]Status: DisposedITAT Bangalore27 Jan 2026AY 2012-13

Bench: Ms. Padmavathy S & Shri Rahul Chaudhary

For Appellant: Ms. Deepashree Rao &For Respondent: Dr. Divya K.J, CIT-DR
Section 250

…ryker Global Technology Centre (P.) Ltd. v. Dy. CIT [2017] 87 taxmann.com 43 (Delhi - Tri.), Samsung Heavy Industries India (P.) Ltd. v. Dy. CIT [2017] 84 taxmann.com 154 (Delhi - Tri.) and Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 66 taxmann.com 192/157 ITD 292 (Delhi - Trib.). 24. All of these decisions pertained to AY 2010-2011. What weighed invariably is the fact that both companies had huge turnovers when compared to the tested entity. Both entities had close connection of the Tata Group of Companies and TCS E-Serve International had given a huge amount to TCS towards brand equity. Further there was…

DCIT, CIRCLE-1(1)(1), , BANGALORE vs. AMAZON DEVELOPEMENT CENTRE (INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeal of the revenue for A

ITA 2036/BANG/2024[2013-14]Status: DisposedITAT Bangalore27 Jan 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Rahul Chaudhary

For Appellant: Ms. Deepashree Rao &For Respondent: Dr. Divya K.J, CIT-DR
Section 250

…ryker Global Technology Centre (P.) Ltd. v. Dy. CIT [2017] 87 taxmann.com 43 (Delhi - Tri.), Samsung Heavy Industries India (P.) Ltd. v. Dy. CIT [2017] 84 taxmann.com 154 (Delhi - Tri.) and Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 66 taxmann.com 192/157 ITD 292 (Delhi - Trib.). 24. All of these decisions pertained to AY 2010-2011. What weighed invariably is the fact that both companies had huge turnovers when compared to the tested entity. Both entities had close connection of the Tata Group of Companies and TCS E-Serve International had given a huge amount to TCS towards brand equity. Further there was…

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

…Genesis international Corporation Ltd. (g) Mould Tek technologies Ltd. We further note that the functional comparability has been examined in detailed by the co-ordinate bench of this Tribunal in the case of Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 157 ITD 292/66 taxmann.com 192 (Delhi - Trib.) as well as in the case of ITO v. Interwoven Software Services (India) (P.) Ltd. [2016] 74 taxmann.com 103 (Bang. - Trib.). Further in the case of Acropetal Technologies Ltd. (Seg.), the co-ordinate bench of this Tribunal in the case of Kodiak Networks (India) Pvt. Ltd. v. Dy. CIT [IT(TP)A No.l540 (Bang) of 2012]…

ALTISOURCE BUSINESS SOLUTIONS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 335/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Mar 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)

…. (f) Genesys International Corpn. Ltd. (g) Mold Tek Technologies Ltd." We further note that the functional comparability has been examined in detailed by the co-ordinate bench of this Tribunal in the case of Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 157 ITD 292/66 taxmann.com 2 (Delhi - Trib.) as well as in the case of ITO v. Interwoven Software Services (India) (P.) Ltd. [2016] 74 taxmann.com 103 (Bang. - Trib.). Further in the case of Acropetal Technologies Ltd. (Seg), the co- ordinate bench of this Tribunal in the case of Kodiak Networks (India) Pvt. Ltd. v. Dy CIT [IT(TP)A No. 1540 (Bang) of 2012] h…

DCIT, BANGALORE vs. M/S ALTISOURCE BUSINESS SOLUTIONS PVT. LTD.,, BANGALORE

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

ITA 178/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Mar 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)

…. (f) Genesys International Corpn. Ltd. (g) Mold Tek Technologies Ltd." We further note that the functional comparability has been examined in detailed by the co-ordinate bench of this Tribunal in the case of Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 157 ITD 292/66 taxmann.com 2 (Delhi - Trib.) as well as in the case of ITO v. Interwoven Software Services (India) (P.) Ltd. [2016] 74 taxmann.com 103 (Bang. - Trib.). Further in the case of Acropetal Technologies Ltd. (Seg), the co- ordinate bench of this Tribunal in the case of Kodiak Networks (India) Pvt. Ltd. v. Dy CIT [IT(TP)A No. 1540 (Bang) of 2012] h…

EMPOWER RESEARCH KNOWLEDGE SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 207/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Dec 2020AY 2011-12

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 92C(2)

…it is nearly 56%. This company has consistent decline in the turnover over the last 3 years. The Ld. AR relied upon the decision of the Tribunal in case of DCIT vs. Xansa India Ltd. (ITA No. 2283/Del/2011) and Equant Solutions India (P.) Ltd. vs. DCIT (2016) 157 ITD 292 (Del) for A.Y. 2010-11. 7.1 The Ld. AR also submitted the inclusion of R Systems International Limited. i) R Systems International Limited: This comparable company is functionally comparable to the assessee company. However, TPO rejected the same on the ground that it is following a different financial year ending. The law provides for the use o…

EMPOWER RESEARCH KNOWLEDGE SERVICES PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 171/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Dec 2020AY 2010-11

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 92C(2)

…it is nearly 56%. This company has consistent decline in the turnover over the last 3 years. The Ld. AR relied upon the decision of the Tribunal in case of DCIT vs. Xansa India Ltd. (ITA No. 2283/Del/2011) and Equant Solutions India (P.) Ltd. vs. DCIT (2016) 157 ITD 292 (Del) for A.Y. 2010-11. 7.1 The Ld. AR also submitted the inclusion of R Systems International Limited. i) R Systems International Limited: This comparable company is functionally comparable to the assessee company. However, TPO rejected the same on the ground that it is following a different financial year ending. The law provides for the use o…

GLOBAL E-BUSINESS OPERATIONS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal of the assessee is treated as allowed

ITA 725/BANG/2017[2012-13]Status: DisposedITAT Bangalore04 Dec 2020AY 2012-13

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.725/Bang/2017 Assessment Year: 2012-13

For Appellant: Shri Sarath Rao, A.RFor Respondent: Shri Sanjay Kumar, D.R
Section 143(3)

…ryker Global Technology Centre (P.) Ltd. v. Dy. CIT [2017] 87 taxmann.com 43 (Delhi - Tri.), Samsung Heavy Industries India (P.) Ltd. v. Dy. CIT [2017] 84 taxmann.com 154 (Delhi - Tri.) and Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 66 taxmann.com 192/157 ITD 292 (Delhi - Trib.). 24. All of these decisions pertained to AY 2010-2011. What weighed invariably is the fact that both companies had huge turnovers when compared to the tested entity. Both entities had close connection of the Tata Group of Companies and TCS E- Serve International had given a huge amount to TCS towards brand equity. Further there wa…

INDECOMM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, assessee’s C

ITA 553/BANG/2015[2010-11]Status: DisposedITAT Bangalore13 Feb 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao, CIT-DR-I
Section 10ASection 143(1)Section 143(3)Section 144C(5)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND SHRI JASON P. BOAZ, ACCOUNTANT MEMBER Appeal No. and APPELLANT RESPONDENT Assessment year IT(TP)A No.404/Bang/2015 The Deputy M/s. Indecomm Global Services 2010-11 Commissioner of India Pvt. Ltd., Income Tax, (formerly known as IGS Imaging Circle - 3(1)(1), Services India Private Limited) Bengaluru. Indecom House, #30, Lasker Road, Augugodi, Banalore – 560 030. PAN : AABCI 2902 H IT(TP)A No.553/Bang/2015 M/s. Indecomm Global The Deputy Commissioner of 2010-11 Services India Pvt. Ltd., Income Tax, Banalore –…

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

…. (f) Genesys International Corpn. Ltd, (g) Mold Tek Technologies Ltd," We further note that the functional comparability has been examined in detailed by the co-ordinate bench of this Tribunal in the case of Equant Solutions India (P.) Ltd. v. Dy. CIT [2016] 157 ITD 292/66 taxmann.com 192 (Delhi - Trib.) as well as in the case of ITO v. Interwoven Software Services (India) (P.) Ltd. [2016] 74 taxmann.com 103 (Bang. - Trib.). Further in the case of Acropetal Technologies Ltd. (Seg.), the co-ordinate bench of this Tribunal in the case of Kodiak Networks (India) Pvt. Ltd. v. Dy. CIT [IT(TP)A No.l540 (Bang) of 2012]…