Swiss Re Global Business Solutions India (P.) Ltd. v. ACIT

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, CIRC-2(1)(1), BANGALORE

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 342/Bang/2022 Assessment Year : 2017-18 M/S. Deliverhealth Solutions India Pvt. Ltd. (Earlier Known As Nuance Transcription Services India Pvt. Ltd.) The Joint First Floor, Block B, Commissioner Of Salarpuria Aura, Income Tax, Khata No. 434/170, Circle 2(1)(1), Marathahalli –Sarjapur Outer Vs. Bangalore. Ring Road, Kaverappa Layout, Kadubeesanahalli, Bangalore – 560 103. Pan: Aaacf3465F Appellant Respondent

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No. 342/Bang/2022 Assessment Year : 2017-18 M/s. Deliverhealth Solutions India Pvt. Ltd. (Earlier known as Nuance Transcription Services India Pvt. Ltd.) The Joint First floor, Block B, Commissioner of Salarpuria Aura, Income Tax, Khata No. 434/170, Circle 2(1)(1), Marathahalli –Sarjapur Outer Vs. Bangalore. Ring Road, Kaverappa Layout, Kadubeesanahalli, Bangalore – 560 103. PAN: AAACF3465F APPELLANT RESPONDENT Assessee by : Shri Vishal Kalra, Advocate Revenue…

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. THE ASSESSING OFFICER, NFAC, DELHI, BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K. JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No.721/Bang/2021 Assessment year : 2016-17 Deliverhealth Solutions India Pvt. Vs. The Assessing Officer, Ltd., Regional e-Assessment Unit, (earlier known as Nuance NFAC, Delhi. Transcription Services Pvt. Ltd.,) First Floor, Block B, Salarpuria Aura, Khata No.434/170, Marathahalli – Sarjapur Outer Rind Road, Kaverappa Layout, Kadubeesanahalli, Bengaluru-560 103. PAN – AAACF 3465 F APPELLANT RESPONDENT Assessee by : Shri Vishal Kalra, Advocate Revenue…

GLOBAL E-BUSINESS OPERATIONS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(3)(2), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri George George K.

…IT(TP)A No.174/Bang/2022 M/s. Global E-Business Operations Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI GEORGE GEORGE K., JUDICIAL MEMBER IT(TP)A No.174/Bang/2022 Assessment Year: 2017-18 M/s. Global E-Business Operations Pvt. Ltd. 1st Floor, Hewlett Packard Deputy Commissioner Enterprise of Income-tax Sy.No.192, Whitefield Road Vs. Circle 5(3)(2) Mahadevpura Post Bangalore Bangalore PAN NO : AABCG2843D APPELLANT RESPONDENT Appellant by : Shri Padam Chand Khincha, A.R. Respondent by : Shri Harinder Kumar, D.R. Dat…

FIREEYE CYBERSECURITY PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 292/Bang/2021 Assessment Year : 2016-17 M/S. Mandiant Cyber Security Pvt. Ltd. (Formerly Known As Fireeye The Deputy Cybersecurity Pvt. Commissioner Of Ltd.), Income Tax, No. 5, Front Wing Circle – 3(1)(1), Salarpuria Infinity, Vs. Bengaluru. 2Nd Floor, Bannerghatta Road, Bengaluru – 560 029. Pan: Aaccf1341A Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri Vilas Shinde, Cit Dr Date Of Hearing : 26-09-2022 Date Of Pronouncement : 10-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Order Passed By National E- Assessment Centre, Delhi Dated 30/04/2021 On Following Revised Grounds Of Appeal:

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No. 292/Bang/2021 Assessment Year : 2016-17 M/s. Mandiant Cyber security Pvt. Ltd. (formerly known as FireEye The Deputy Cybersecurity Pvt. Commissioner of Ltd.), Income Tax, No. 5, Front Wing Circle – 3(1)(1), Salarpuria Infinity, Vs. Bengaluru. 2nd Floor, Bannerghatta Road, Bengaluru – 560 029. PAN: AACCF1341A APPELLANT RESPONDENT : Shri T. Suryanarayana, Assessee by Senior Advocate Revenue by : Shri Vilas Shinde, CIT DR Date of Hearing : 26-09-2022 Date of P…

OCWEN FINANCIAL SOLUTIONS PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-5, BANGALORE

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

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.342/Bang/2021 : Asst.Year 2016-2017 M/S.Ocwen Financial Solutions The Assistant Commissioner Private Limited Of Income-Tax V. Pritech Park, Survey No.51 To Special Range – 5 64/4, Block No.12, Unit 2, 5B & Bangalore. 6A Floors, Bellandur Village, Sarjapur Marathahalli Ring Road Bengaluru – 560 103. Pan : Aaaco3764E. (Appellant) (Respondent) Appellant By : Sri.Ankur Pai & Sri. K.R.Vasudevan, Advocates Respondent By : Sri.K.Sankar Ganesh, Jcit-Dr Date Of Pronouncement : 14.10.2022 Date Of Hearing : 13.10.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Providing It Enabled Services To Ocwen Mortgage Servicing Inc. Usvi. The Assessee Is A Wholly Owned Subsidiary Of Ocwen Asia Holdings Limited, Mauritius. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 29.11.2016 Declaring Total Income Of Rs.93,31,44,800. The Case Was Selected For Scrutiny

…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.342/Bang/2021 : Asst.Year 2016-2017 M/s.Ocwen Financial Solutions The Assistant Commissioner Private Limited of Income-tax v. Pritech Park, Survey No.51 to Special Range – 5 64/4, Block No.12, Unit 2, 5B & Bangalore. 6A Floors, Bellandur Village, Sarjapur Marathahalli Ring Road Bengaluru – 560 103. PAN : AAACO3764E. (Appellant) (Respondent) Appellant by : Sri.Ankur Pai & Sri. K.R.Vasudevan, Advocates Respondent by : Sri.K.Sankar Ganesh, JCIT-DR Date of Pronouncement : 14.1…

HP PPS SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 278/Bang/2021 Assessment Year : 2016-17 M/S. Hp Pps Services India Pvt. Ltd., The Deputy No. 24, Salarpuria Commissioner Of Arena, Income Tax, Hosur Main Road, Circle 3 (1)(1), Adugodi, Vs. Bangalore. Bangalore – 560 030. Pan: Aadch5825N Appellant Respondent : Shri Padamchand Assessee By Khincha, Ca : Shri Binod Kumar Singh, Revenue By Cit Dr Date Of Hearing : 22-08-2022 Date Of Pronouncement : 29-09-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 29/03/2021 Passed By National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal. “The Appellant Submits That: I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp')

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No. 278/Bang/2021 Assessment Year : 2016-17 M/s. HP PPS Services India Pvt. Ltd., The Deputy No. 24, Salarpuria Commissioner of Arena, Income Tax, Hosur Main Road, Circle 3 (1)(1), Adugodi, Vs. Bangalore. Bangalore – 560 030. PAN: AADCH5825N APPELLANT RESPONDENT : Shri Padamchand Assessee by Khincha, CA : Shri Binod Kumar Singh, Revenue by CIT DR Date of Hearing : 22-08-2022 Date of Pronouncement : 29-09-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appe…

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

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

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “B”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM IT(TP)A No.212/Bang/2021 : Asst.Year 2016-2017 M/s.Global E-Business The Deputy Commissioner of Operations Private Limited Income-tax, Circle 3(1)(1) v. Bangalore. 1st Floor, Hewlett Packard Enterprises, Sy No.192, Whitefield Road, Mahadevpura Post Bangalore – 560 048. PAN : AABCG2843D. (Appellant) (Respondent) Appellant by : Sri.P.C.Kincha, CA Respondent by : Sri.Manjunath Karkihalli, CIT-DR Date of Pronouncement : 27.09.2022 Date of Hearing : 26.09.2022 O R D E R Per George George K, JM :…

EIT SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…IT(TP)A No.210/Bang/2021 EIT Services India Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.210/Bang/2021 Assessment Year: 2016-17 EIT Services India Pvt. Ltd. Digital Park, 39/40, Electronic Deputy Commissioner of City Income-tax Phase II Hosur Road Vs. Circle 2(1)(1) Bangalore 560 100 Bangalore PAN NO : AAACD4078L APPELLANT RESPONDENT Appellant by : Shri Padam Chand Khincha, A.R. Respondent by : Shri Praveen Karanth, D.R. Date of Hearing : 27.07.2022 Date of Pronouncement :…