“working capital adjustment”

Transfer PricingSection 92CSection 92C508 judgments

The decision most relied on for working capital adjustment is Sony India (P) Ltd. v. DCIT (114 ITD 448), cited in 131 judgments on BharatTax.

Leading authorities on working capital adjustment

Sony India (P) Ltd. v. DCIT

114 ITD 448 · 2008 · ITAT

131

citing judgments

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

Pr. CIT v. Kusum Health Care Pvt. Ltd.

398 ITR 66 · 2017 · High Court

100

citing judgments

Not every item of receivables appearing in the accounts of an entity dealing with foreign associated enterprises automatically constitutes an international transaction under Section 92B. A separate adjustment for interest on outstanding receivables is not permissible if the working capital adjustment has already factored in their impact.

Mentor Graphics (Noida) (P) Ltd. v. DCIT

109 ITD 101 · 2007 · ITAT

citing judgments

A working capital adjustment is mandated and a prerequisite for correctly determining the Arm's Length Price (ALP) under Rule 10B(1)(e) and Rule 10B(3) of the Income Tax Rules, 1962. This adjustment accounts for differences in working capital and outstanding receivables between the assessee and comparable companies.

Avenue Asia Advisors Pvt. Ltd. v. DCIT

398 ITR 120 · 2017 · High Court

citing judgments

The Delhi High Court holds that a detailed functional and working capital analysis, considering various factors, is essential before treating outstanding receivables as a separate international transaction for transfer pricing adjustments on notional interest. Simply making an adjustment based on receivables alone without such study distorts the transaction's character.

Indo Rama Synthetics (I) Ltd. v. CIT

330 ITR 363 · 2011 · Supreme Court

citing judgments

For Minimum Alternate Tax (MAT) under Section 115JB, the book profit must reflect the true working results of the company. Capital receipts that are not income cannot be included in book profit, and adjustments based on notes on accounts can be made to arrive at the real profit.

Huawei Technologies India Pvt. Ltd. v. JCIT

101 Taxmann.com 313 · 2019 · ITAT

citing judgments

Working capital adjustments are permissible and crucial for comparability analysis when determining the arm's length price of international transactions, especially when an assessee's claim for such adjustment has been denied.

ITO v. E Value Serve.com

75 Taxmann.com 195 · 2016 · Reported

citing judgments

In transfer pricing analysis, demanding daily balances for working capital adjustments is impractical and improper; adjustments should be based on opening and closing working capital. Transfer pricing inherently involves estimation to ensure comparability.

Genesis Integrating Systems India Pvt Ltd. v. DCIT

53 SOT 159 · 2012 · ITAT

citing judgments

Companies with significantly different turnovers (e.g., one above Rs. 200 crores and another below) cannot be considered comparable in transfer pricing analysis. Turnover is a relevant factor in assessing comparability.

Judgments citing working capital adjustment

M/S Dell International Services India Private Limited, Bangalore vs. Joint Commissioner of Income Tax Ltu, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 932/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.844/Bang/2017 Assessment Year : 2012-13 The Joint Vs. M/S.Dell International Services India Commissioner Of Private Limited, Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent It(Tp)A No.932/Bang/2017 Assessment Year : 2012-13 M/S.Dell International Services Vs. The Joint Commissioner India Private Limited, Of Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent Revenue By : Shri Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Assessee By : Shri T. Suryanarayana, Advocate Date Of Hearing : 07.11.2022 Date Of Pronouncement : 14.11.2022

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri

Section 143(2)Section 92C

computed the arm’s length price (ALP) to arrive at the TP adjustment as under:- Arm’s Length Mean Mark-up 22.63% Less: Working Capital Adjustment 2.30% Adjusted mean mark-up of the comparables 20.33% Operating Cost Rs. 1211,09,64,036/- IT(TP)A Nos.844 & 932/Bang/2017 Page ... computed the arm’s length price (ALP) to arrive at the TP adjustment as under:- Arm’s Length Mean Mark-up 28.11% Less: Working Capital Adjustment -0.57% Adjusted mean mark-up of the comparables 28.68% Operating Cost Rs. 990,84,77,671/- Arm’s Length Price – 120.33% of Operating Cost

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Private Limited, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 844/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri

Section 143(2)Section 92C

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Pvt Ltd, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 134/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

only issue contended by the revenue with regard to the transfer pricing adjustment is direction given by the CIT(A) to allow working capital adjustment for marketing support services. This issue does not warrant separate adjudication in view of the decision on the TP issues while considering the assessee

M/S Dell International Services India Pvt Ltd, Bangalore vs. Joint Commisssioner of Income Tax Ltu, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 2834/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

Dell International Services India Private Limited, Bangalore vs. JCIT, Bangalore

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

ITA 642/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144CSection 92CSection 92C(3)

differences in (i) accounting practices, (ii) marketing expenditure adjustment, (iii) research and development expenditure adjustment, (iv) working capital, (iv) risk profile and (v) working capital adjustment to account between the Appellant and the comparable companies. 8. Variation of 5% from the arithmetic mean The AO/ TPO erred

JCIT, Bangalore vs. M/S Dell International Services India Pvt. Ltd., Bangalore

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

ITA 641/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Sri.Pradeep Kumar, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144CSection 92CSection 92C(3)

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

ITA 292/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Nov 2022AY 2016-17

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:

For Respondent: Shri T. Suryanarayana

hence it is an international transaction as per explanation to section 92 B of the Act. Alternatively, it has been argued that working capital adjustment subsumes sundry creditors. In such situation computing interest on outstanding receivables and lones and advances to international transaction would amount to double taxation

Travelex India P.Ltd, Mumbai vs. Asst CIT 13(3)(2), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1214/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Nov 2022AY 2010-11

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 144C(5)Section 92C

data used by the Appellant to compute the Profit Level Indicator ("PLI) and adopting an entity level PLI; and h. not allowing a working capital adjustment and risk adjustment 6 ITA NOs. 1214/MUM/2015 (A.Y: 2010-11) Travelex India Private Limited The Appellant prays that the appropriate relief be granted

Eversendai Construction Private Limited, Chennai vs. DCIT Corporate Circle 2(1), Chennai

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

ITA 2084/CHNY/2017[2013-14]Status: DisposedITAT Chennai04 Nov 2022AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2084/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 M/S.Eversendai Construction- V. The Dy. Commissioner- Pvt. Ltd., Of Income Tax, Plot No.1 & 2, The Lords, Corporate Circle-2(1), Block-1, 5Th Floor, Chennai. Thiru-Vi-Ka Industrial Estate, Jawaharlal Nehru Road, Ekkaduthangal, Guindy, Chennai.

For Appellant: Mr.S.P.Chidambaram, AdvFor Respondent: Dr.S.Palanikumar, CIT

Section 143(3)Section 144C(5)

AO/DRP erred in confirming the order of the TPO in treating foreign exchange loss suffered by the Appellant as operating expense. Working Capital Adjustment: 2.9 The AO/DRP erred in confirming the order of the TPO in not providing working capital adjustment while determining the net profit margins of the appellant ... AO/DRP erred in confirming the order of the TPO in rejecting the working capital adjustment without appreciating the fact that the TPO failed to take cognizance of the detailed workings provided. Capacity utilization adjustment: 2.11 The AO/DRP erred in rejecting the capacity utilization adjustment claimed by the Appellant while determining

Aquity Solutions India Pvt.Ltd(Formerly Known As Mmodal Global Services Pvt. Ltd, Mumbai vs. Dy.Ci.T.15(1) (1), Mumbai

In the result, appeal by the assessee is partly allowed

ITA 713/MUM/2022[2017-18]Status: DisposedITAT Mumbai02 Nov 2022AY 2017-18

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Harsh ShahFor Respondent: Ms. Samruddhi D. Hande

Section 144BSection 144C(13)Section 144C(3)Section 144C(5)

made on comparable data for provision of Medical Transcription (MT) services, the Assessee's transactions were yet at arm's length. b. Once working capital adjustment was made on comparable date for provision of IT and IT enabled services (IT & ITeS), the Assessee's transactions were ... respect of provision of IT and IT enabled services segment, learned AR submitted that this transaction was benchmarking considering the working capital adjusted margins of the comparable companies and assessee was found to be at arm‟s length, therefore, impact of delayed receivables has already been factored in, requiring

Munich Re India Service P.Ltd, Mumbai vs. Asst CIT Cir 6(3), Mumbai

In the result, appeal of the assessee is dismissed as withdrawn

ITA 2126/MUM/2015[2009-10]Status: DisposedITAT Mumbai02 Nov 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: NoneFor Respondent: Shri. Samuel Pitta

Section 92C(3)

risks assumed by the assessee vis-à-vis the comparables selected by ld TPO. Munich Re India Pvt. Ltd.; A.Y. 2009-10 7. Working Capital Adjustment not granted On the facts and in the circumstances of the case and in law, the Ld. CIT(A) end in upholding/confirming the action ... granting the working capital adjustment as mandated in Rule 10B(3) of the Rules. 8. Risk Adjustment not granted The Ld. CIT(A) farther erred in upholding/confirming the action of the TPO by not granting any risk adjustment to the appellant thereby violating the provisions of Rule

M/S. Ig Infotech (India) Private Limited, Bengaluru vs. Assistant Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal of the assessee is allowed

ITA 204/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 143(3)Section 144BSection 144C(13)Section 92C

companies in respect of the subject transaction. 6.1 The grievance of the assessee in this ground is with regard to non-granting of working capital adjustment. 6.2 After hearing both the parties, we are of the opinion that this issue came for consideration before this Tribunal in the case ... light of the above discussion we are of the view that the CIT(A) was not justified in denying adjustment on account of working capital adjustment. Since, the CIT(A) has not found any error in the TPO’s working of working capital IT(TP)A No.204/Bang/2022 IG Infotech (India

M/S. Biesse Manufacturing Company Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

In the result, the appeal of the assessee is partly allowed

ITA 338/BANG/2021[2016-17]Status: DisposedITAT Bangalore31 Oct 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri, Tata Krishna, AdvocateFor Respondent: Shri Sankar K. Ganeshan, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 234ASection 234BSection 92C

distinguished its earlier order in the case of Kusum Healthcare Pvt. Ltd. (supra) and rejected the contention that interest gets subsumed in the working capital adjustment. The Hon`ble Bombay High court in the case of CIT vs. Patni Computer Systems Ltd, (2013) 215 Taxman 108 (Bom) dealt, inter alia

Medreich Limited, Bangalore vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

ITA 451/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 451/Bang/2022 Assessment Year : 2017-18 M/S. Medreich Ltd., No. 12/8, Medreich The Assistant House, Commissioner Of Saraswati Ammal Income Tax, Street, Central Circle – Maruti Seva Nagar, 1(2), Vs. Bangalore – 560 033. Bangalore. Pan: Aabcm1458Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Ld.Acit, Central Circle – 1(2), Bangalore Dated 26/04/2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “General Ground 1.1 The Learned Assistant Commissioner Of Income Tax, Central Circle-1(2), Bangalore (`A0') Erred In Passing The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (`The Act) In The Manner Passed

For Respondent: Shri Padam Chand

Section 143(3)Section 14ASection 92B

receivable; c) not restricting the computation of interest on delayed receivables to the interest accruing for the year under consideration; d) not providing working capital adjustment as prescribed under rule 10B of the Income Tax Rules, 1962. 4.3 The learned TPO and Hon'ble DRP failed to appreciate that ... relating to outstanding receivables cannot be benchmarked separately; b) no interest was charged to non-AE's for similar transactions;. c) on providing working capital adjustment no adjustment is required to be made for notional interest on outstanding receivables. 4.4 On the facts and circumstances of the case

Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

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

ITA 350/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Ankur Pai, AdvocateFor Respondent: Shri

Section 143(2)Section 143(3)Section 92C

Mfx Infotech Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 4(1)(2), Bangalore

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

ITA 251/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Manjunath Karkihalli, CIT-DR

Section 133(6)Section 143(3)Section 144B

cogent reasons. (e) not allowing appropriate adjustments under Rule 10B to account for, inter alia, differences in (i) accounting practice; (ii) positive working capital adjustment; (iii) risk profile between the Appellant and the comparable companies, if favourable to the Appellant. 18. On facts and circumstances of the case ... applicable to the facts of the case. 22. Without prejudice, no separate adjustment for interest on delayed receivables is required when (i) working capital adjustment is given; or (ii) where the margins of the international transaction is held to be at arms-length price.” 3. The assessee is engaged

Parexel International Clinical Research Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(1)(2), Bangalore

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

ITA 189/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 189/Bang/2021 Assessment Year : 2016-17 M/S. Parexel International Clinical Research Pvt. Ltd., Cowrks, Rmz The Assistant Ecoworld, Ground Commissioner Of Floor, Bay Area- Income Tax, Adjacent To Building Circle 5(1)(2), 6A, Outer Ring Road, Vs. Bangalore. Devarabeesanahalli Village, Bangalore – 560 103. Pan: Aadcp9318C Appellant Respondent Assessee By : Ms. Chandini Shah, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Passed By National E-Assessment Centre, Delhi Dated 26/03/2021 For A.Y. 2016-17 On Following Grounds Of Appeal:

For Appellant: Ms. Chandini Shah, CA

Section 92C

company from the list. Accordingly, Ground no. 4 raised by assessee stands allowed partly. 7. Ground no. 5 is raised by assessee seeking working capital adjustment. It is submitted that Coordinate Bench of this Tribunal in assessee’s own case for A.Y. 2014-15 have granted Working Capital Adjustment ... observing as under: “21. The next ground raised by the assessee is with respect to not granting working capital adjustment. The assessee for the relevant assessment year has considered 14.59% towards working capital adjustment taking State Bank of India’s primary lending rate as the basis. The justification for such

M/.S Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by assessee stands allowed in respect of the issues argued and considered hereinabove

ITA 2595/BANG/2019[2015-16]Status: DisposedITAT Bangalore21 Oct 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2595/Bang/2019 Assessment Year : 2015-16 M/S. Synamedia India Pvt. Ltd., Block 9A & 9B, The Deputy Pritech Park, Commissioner Of Survey No. 51-64/4, Income Tax, Sarjapur Outer Ring Circle – 6(1)(2), Road, Bengaluru. Vs. Bellandur Village, Bengaluru – 560 103. Pan: Aaccn1140K Appellant Respondent Assessee By : Shri Ankur Pai, Advocate : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 28-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 29/10/2019 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal:

For Appellant: Shri Ankur Pai, Advocate

Section 143(2)

observed that payments to assessee are not contingent upon payment received by AEs from their respective customers. Further Ld.AR submitted that working capital adjustment undertaken by assessee includes the adjustment regarding the receivables and thus receivables arising out of such transaction have already been accounted for. Alternatively, he submitted that ... extending credit period with mutual consent and it does not provide any interest clause in case of delay. He also argued that the working capital adjustment takes into account the factors related to delayed receivables and no separate adjustment is required in such circumstances. 20.5 On the contrary Ld.CIT.DR submitted

Lloyds Offshore Global Services Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeals for AYs 2015-16 and 2016-17 are partly allowed

ITA 194/BANG/2021[2016-17]Status: DisposedITAT Bangalore20 Oct 2022AY 2016-17

Bench: Smt Beena Pillai. & Ms. Padmavathy S

For Appellant: Shri Chavali Narayan, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)

after considering the directions given in the above paragraphs of this order after giving a reasonable opportunity of being heard to the assessee. Working capital adjustment 36. The ld AR submitted that – i. The Rules provide that a transaction can be considered as comparable, if reasonably accurate adjustments ... effect of any such differences. These are called "comparability adjustments. 13. In Paragraphs 13 to 16 of the aforesaid DECO guidelines, need for working capital adjustment has been explained as follows: "13. In a competitive environment, money has a time value. If a company provided, say, 60 days trade terms

M/S. Lloyds Offshore Global Services Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore

In the result, the appeals for AYs 2015-16 and 2016-17 are partly allowed

ITA 27/BANG/2020[2015-16]Status: DisposedITAT Bangalore20 Oct 2022AY 2015-16

Bench: Smt Beena Pillai. & Ms. Padmavathy S

For Appellant: Shri Chavali Narayan, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)