Genisys Integrating System v DCIT 15 ITR Trib 475, Kodiak Networks v. ACIT

23 ITR (Trib) 464Income Tax Appellate Tribunal#7062 most cited
16

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2022.

Judgments citing Genisys Integrating System v DCIT 15 ITR Trib 475, Kodiak Networks v. ACIT

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE vs. M/S. HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED( FORMERLY KNOWN AS SYMPHONEY TELECA CORPORATION INDIA PRIVATE LIMITED), BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 631/BANG/2016[2011-12]Status: DisposedITAT Bangalore16 Dec 2022AY 2011-12

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.631/Bang/2016 : Asst.Year 2011-2012 The Deputy Commissioner Of M/S.Harman Connected Income-Tax, Circle 3(1)(2) Services Corporation India V. Bangalore. Private Limited (Formerly Symphony Telca Corporation India Pvt. Ltd.) No.3 & 3A, Eoiz Industrial Area, Survey No.85 & 86, Sadarmangala Village, K.R.Puram, Hobli Bangalore – 560 066 Pan : Aabcg5658E. (Appellant) (Respondent) Appellant By : Smt.Tanmayee Rajkumar, Advocate Respondent By : Sri.K.Sankar Ganesh, Jcit-Dr Date Of Pronouncement : 16.12.2022 Date Of Hearing : 15.12.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Revenue Is Directed Against Final Assessment Order Dated 29.01.2016 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2011-2012. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Incorporated Under The Companies Act, 1956. The Assessee Is Engaged In Providing Software Development Services To Its Group Companies As Well As Third Parties. For The Assessment Year 2011-2012, The Return Of Income Was Filed On 30.11.2011 Declaring Gross Total

For Appellant: Smt.Tanmayee Rajkumar, AdvocateFor Respondent: Sri.K.Sankar Ganesh, JCIT-DR
Section 10ASection 143(2)Section 143(3)Section 40Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “A”, BANGALORE Before Shri George George K, JM & Shri Laxmi Prasad Sahu, AM IT(TP)A No.631/Bang/2016 : Asst.Year 2011-2012 The Deputy Commissioner of M/s.Harman Connected Income-tax, Circle 3(1)(2) Services Corporation India v. Bangalore. Private Limited (Formerly Symphony Telca Corporation India Pvt. Ltd.) No.3 & 3A, EOIZ Industrial Area, Survey No.85 & 86, Sadarmangala Village, K.R.Puram, Hobli Bangalore – 560 066 PAN : AABCG5658E. (Appellant) (Respondent) Appellant by : Smt.Tanmayee Rajkumar, Advocate Respondent by : Sri.K.Sankar Ganesh, JCIT-DR Date of P…

INCOME TAX OFFICER, WARD-11(2), BANGALORE vs. M/S IPASS INDIA P LTD, BANGALORE

In the result,Revenue’s appeal for Assessment Year 2009-10 is dismissed

ITA 1310/BANG/2014[2009-10]Status: DisposedITAT Bangalore04 Sept 2015AY 2009-10

Bench: Shri Vijaypal Rao & Shri Jason P. Boazi.T.(T.P) A. No.1292/Bang/2014 (Assessment Year : 2009-10) M/S. Ipass India Pvt. Ltd. Vs. Income Tax Officer, Unit 501, Level V, Ward 11(2), Bangalore. No.6, Brunton Road, Bangalore-560 001 Pan Aabcg 3659H Appellant Respondent. I.T.(T.P) A. No.1310/Bang/2014 (Assessment Year : 2009-10) (By Revenue) Assessee By : Shri Chavali Narayan, C.A. Revenue By : Dr.P.K. Srihari, Addl. Cit (D.R.) Date Of Hearing : 9.7.2015. Date Of Pronouncement : 4.9.2015. O R D E R Per Shri Jason P. Boaz, A.M. : These Are Cross Appeals, One Each By The Assessee & Revenue, Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-Iv, Bangalore Dt.18.8.2014 For Assessment Year 2009-10. 2. The Facts Of The Case, Briefly, Are As Under :- 2.1 The Assessee Company Is A Wholly Owned Subsidiary Of Ipass Inc., Usa Providing Captive Software Development Support Services For Its Associated Enterprise (Ae) In Usa

For Appellant: Shri Chavali Narayan, C.AFor Respondent: Dr.P.K. Srihari, Addl. CIT (D.R.)
Section 10ASection 143(1)Section 143(3)Section 92C

…e case of the assessee, by applying the principles emerging from the orders of the Delhi Bench of the Hon'ble Tribunal in Haworth (India) Pvt. Ltd. V DCIT 11 ITR (Trib) 757 and the Bangalore Bench of the Hon'ble Tribunal in Triology E-Business Software V DCIT 23 ITR (Trib) 464 without appreciating that in transfer pricing every case is unique and requires to be decided independently and that the directions issued are beyond the mandate of the provisions of Section 251(1)(a) of the IT Act which does not empower the CIT (Appeals) to set aside the issue. 5. For these and such other grounds that may be urged at the t…

IPASS INDIA PVT LTD,BANGALORE vs. INCOME TAX OFFICER, WARD-11(2), BANGALORE

In the result,Revenue’s appeal for Assessment Year 2009-10 is dismissed

ITA 1292/BANG/2014[2009-10]Status: DisposedITAT Bangalore04 Sept 2015AY 2009-10

Bench: Shri Vijaypal Rao & Shri Jason P. Boazi.T.(T.P) A. No.1292/Bang/2014 (Assessment Year : 2009-10) M/S. Ipass India Pvt. Ltd. Vs. Income Tax Officer, Unit 501, Level V, Ward 11(2), Bangalore. No.6, Brunton Road, Bangalore-560 001 Pan Aabcg 3659H Appellant Respondent. I.T.(T.P) A. No.1310/Bang/2014 (Assessment Year : 2009-10) (By Revenue) Assessee By : Shri Chavali Narayan, C.A. Revenue By : Dr.P.K. Srihari, Addl. Cit (D.R.) Date Of Hearing : 9.7.2015. Date Of Pronouncement : 4.9.2015. O R D E R Per Shri Jason P. Boaz, A.M. : These Are Cross Appeals, One Each By The Assessee & Revenue, Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-Iv, Bangalore Dt.18.8.2014 For Assessment Year 2009-10. 2. The Facts Of The Case, Briefly, Are As Under :- 2.1 The Assessee Company Is A Wholly Owned Subsidiary Of Ipass Inc., Usa Providing Captive Software Development Support Services For Its Associated Enterprise (Ae) In Usa

For Appellant: Shri Chavali Narayan, C.AFor Respondent: Dr.P.K. Srihari, Addl. CIT (D.R.)
Section 10ASection 143(1)Section 143(3)Section 92C

…e case of the assessee, by applying the principles emerging from the orders of the Delhi Bench of the Hon'ble Tribunal in Haworth (India) Pvt. Ltd. V DCIT 11 ITR (Trib) 757 and the Bangalore Bench of the Hon'ble Tribunal in Triology E-Business Software V DCIT 23 ITR (Trib) 464 without appreciating that in transfer pricing every case is unique and requires to be decided independently and that the directions issued are beyond the mandate of the provisions of Section 251(1)(a) of the IT Act which does not empower the CIT (Appeals) to set aside the issue. 5. For these and such other grounds that may be urged at the t…