← All Phrases

“multiple year data”

Transfer PricingSection 92CSection 92C149 judgments

The decision most relied on for multiple year data is Electronic for Imaging (I) Pvt. Ltd. v. DCIT (85 Taxmann.com 124), cited in 38 judgments on BharatTax.

Leading authorities on multiple year data

Electronic for Imaging (I) Pvt. Ltd. v. DCIT
85 Taxmann.com 124 · 2017 · ITAT
38
citing judgments

Comparability of a company for transfer pricing purposes must be decided afresh by the TPO after considering the facts recorded in prior tribunal decisions. The tribunal may direct exclusion of comparable companies based on such prior decisions.

Orange Business Services India Solutions (P.) Ltd. v. Dy. CIT
91 Taxmann.com 286 · 2018 · High Court
26
citing judgments

A company is considered a comparable in transfer pricing analysis unless it is shown to be functionally incomparable.

DCIT v. Rehau Polymers Pvt. Ltd.
85 Taxmann.com 23 · 2017 · Reported
17
citing judgments

The case is cited for principles related to transfer pricing, likely concerning the benchmarking analysis of related party transactions, as indicated by the accompanying topics and keywords.

Judgments citing multiple year data

Polycom Technology ( R & D ) Center P. Ltd, Hyderabad vs. DCIT Cir 7(3)(2), Mumbai

In the result, appeal of the assessee for A

ITA 2067/MUM/2017[2012-13]Status: DisposedITAT Mumbai26 Jul 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri M. P. Lohia & Shri MihirFor Respondent: Ms. Vatsalaa Jha, CIT DR
Section 143(3)Section 144CSection 92C

appellant's international transactions holding that the impugned international transaction is not at arm's length and Rejection of use of multiple-year data by the appellant: 5. erred determining the arm's length margins / prices using data pertaining only to financial Year (FY) 2011-12 (not available ... appellant at the time of complying with the Indian TP documentation requirements) and rejecting the use of multiple year data by the appellant not Erroneous re- characterization of the appellant's functional profile: 6. erred in characterizing the appellant as contract R&D service provider instead of contract software development

DCIT 2(3), Mumbai vs. Tech Mahindra P.Ltd, Mumbai

In the result, appeal by the assessee is allowed for statistical purpose, while the appeal by the Revenue is dismissed

ITA 3033/MUM/2014[2008-09]Status: DisposedITAT Mumbai26 Jul 2022AY 2008-09

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri H.P. MahajaniFor Respondent: Shri Chandra Vijay
Section 10ASection 250Section 2D

tested party as well as introducing her own comparables from a database available to her herein India. Moreover, the assessee relied on multiple year data without demonstrating its impact in the current year, whereas the TPO was in a position to determine ALP on the basis of current year data

Sitel India Ltd, Mumbai vs. DCIT RG 8(3), Mumbai

In the result, appeal by the assessee is allowed

ITA 6875/MUM/2014[2007-08]Status: DisposedITAT Mumbai19 Jul 2022AY 2007-08

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ajit Jain a/wFor Respondent: Shri Tejinder Pal Singh
Section 10ASection 143(3)Section 195Section 250Section 271(1)(c)Section 40

impugned order, learned CIT(A) has upheld the penalty levied on transfer pricing adjustment on the basis that assessee has taken multiple year data of the companies selected as comparables, which is against the provisions of Rule 10B(4). The learned CIT(A) vide impugned order also find fault with

ACIT Cir 1, Thane vs. Lanxess India P.Ltd, Thane

ITA 2788/MUM/2014[2009-10]Status: DisposedITAT Mumbai18 Jul 2022AY 2009-10

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10 Lanxess India Private Limited, Asst. Commissioner Of Income-Tax, Lanxess House, Plot No. 162-164, Circle 1, Road No. 27, Wagle Estate, Opp. Iti Vs. 6Th Floor, Asher It Park, Road No. College, Midc, 16-Z, Wagle Industrial Estate, Thane-(West)-400604. Thane. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income-Tax, Lanxess India Private Limited, Circle 1, Lanxess House, Plot No. 162-164, 6Th Floor, Asher It Park, Road No. 16- Vs. Road No. 27, Wagle Estate, Opp. Iti Z, Wagle Industrial Estate, College, Midc, Thane. Thane-(West)-400604 Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Mr. Pratik Shah/For Respondent: Mr. V.K. Agarwal, CIT-DR
Section 143(3)Section 144C(13)

companies engaged in manufacturing of chemicals manufacturing of chemicals and identified 10 comparable identified 10 comparables having arithmetic mean (OP/Sales) of 5.73% using multiple year data mean (OP/Sales) of 5.73% using multiple year data mean (OP/Sales) of 5.73% using multiple year data. The Ld. TPO directed the assessee

Lanxess India P.Ltd, Thane vs. Asst CIT Cir 1, Thane

ITA 2628/MUM/2014[2009-10]Status: DisposedITAT Mumbai18 Jul 2022AY 2009-10

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10 Lanxess India Private Limited, Asst. Commissioner Of Income-Tax, Lanxess House, Plot No. 162-164, Circle 1, Road No. 27, Wagle Estate, Opp. Iti Vs. 6Th Floor, Asher It Park, Road No. College, Midc, 16-Z, Wagle Industrial Estate, Thane-(West)-400604. Thane. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income-Tax, Lanxess India Private Limited, Circle 1, Lanxess House, Plot No. 162-164, 6Th Floor, Asher It Park, Road No. 16- Vs. Road No. 27, Wagle Estate, Opp. Iti Z, Wagle Industrial Estate, College, Midc, Thane. Thane-(West)-400604 Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Mr. Pratik Shah/For Respondent: Mr. V.K. Agarwal, CIT-DR
Section 143(3)Section 144C(13)

companies engaged in manufacturing of chemicals manufacturing of chemicals and identified 10 comparable identified 10 comparables having arithmetic mean (OP/Sales) of 5.73% using multiple year data mean (OP/Sales) of 5.73% using multiple year data mean (OP/Sales) of 5.73% using multiple year data. The Ld. TPO directed the assessee

Altico Capital India Private Limited ( Formerly Clearwater Capital Partners (I) Private Limited, Mumbai vs. ACIT Circle-14(1)(2), Mumbai

In the result, cross appeals by the assessee and Revenue are partly allowed

ITA 424/MUM/2018[2011-12]Status: DisposedITAT Mumbai04 Jul 2022AY 2011-12

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur Agrawal a/wFor Respondent: Shri Rajesh Kumar Yadav, Sr. AR
Section 250

which was neither a comparable in Appellant's set nor in learned TPO's set; 4.3 In rejecting the use of contemporaneous and multiple year data available for computing the ALP as on the date of filing of return of income and relying on the single year data

Jt.Commissioner of Income Tax (OSD)- 14(1)(1), Mumbai vs. Clearwater Capital Partners India Private Limited (Now Known As Altico Capital India Private Limited, Mumbai

In the result, cross appeals by the assessee and Revenue are partly allowed

ITA 11/MUM/2018[2011-12]Status: DisposedITAT Mumbai04 Jul 2022AY 2011-12

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur Agrawal a/wFor Respondent: Shri Rajesh Kumar Yadav, Sr. AR
Section 250

which was neither a comparable in Appellant's set nor in learned TPO's set; 4.3 In rejecting the use of contemporaneous and multiple year data available for computing the ALP as on the date of filing of return of income and relying on the single year data

Deputy Commissioner of Income Tax Circle-1(1)(1), Bangalore vs. M/S Altisource Business Solutions India Pvt Ltd, Bangalore

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

ITA 164/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Jun 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 162/Bang/2018 Assessment Year : 2012-13 M/S. Altisource Business Solutions Pvt. Ltd., Pritech Park, 3Rd & 5Th Floors Of Wing A & The Deputy 4Th Floor Of Wing B, Commissioner Of Block No. 12, Pritech Park, Income Tax, Survey No. 51-64/4, Circle – 1 (1)(2), Bellandur Village, Bangalore. Vs. Sarjapur Marathahalli Outer Ring Road, Bangalore – 560 103. Pan: Aaaco9467A Appellant Respondent & It(Tp)A No. 164/Bang/2018 Assessment Year : 2012-13 (By Revenue) : Shri K.R. Vasudevan, Assessee By Advocate : Smt. Susan Dolores George Revenue By Cit (Osd) Date Of Hearing : 30-05-2022 Date Of Pronouncement : 29-06-2022 Order Per Beena Pillaipresent Cross Appeals Filed By The Assessee & The Revenue Against Order Dated 31.08.2017 Passed By The Ld.Cit(A)-1, Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal:

Section 92C(3)(a)

learned CIT(A) has erred in law and facts, by upholding action of the learned AO/TPO of rejecting the use of multiple year data adopted by the Appellant for determining the arm's length price of the international transactions; 5. The learned CIT(A) has erred in law and facts

Enstage Software Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

The appeal of the assessee is partly allowed

ITA 260/BANG/2021[2016-17]Status: DisposedITAT Bangalore13 Jun 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.260/Bang/2021 Assessment Year : 2016-17 M/S. Enstage Software Private Limited, Dcit (Exemptions), Vs. 16/1, Wings, 2Nd Floor, Circle – 2(1)(1), Cambridge Road, Halsuru, Bengaluru. Bengaluru – 560 008. Pan : Aaace 9963 B Appellant Respondent

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)(ITAT), Bengaluru
Section 143(3)Section 92(1)Section 92B(1)Section 92C

look at the amendment to the rules that allow for introduction of a “range concept” for determination of ALP and “use of multiple year data” for undertaking comparability analysis in transfer pricing cases. The provisions of the Income-tax Act were amended through the Finance (No.2) Act, 2014 to facilitate ... after PY 2014-15. The amended rules allow for introduction of a “range concept” for determination of ALP and “use of multiple year data” for undertaking comparability analysis in transfer pricing cases. The use of range concept being a statistical tool enhances the reliability of analysis undertaken for computation

Dow Chemicals International Pvt Ltd. As Successor of Rohm and Haas (India) Pvt Ltd, Mumbai vs. ITO 14 (1)(3), Mumbai

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

ITA 7936/MUM/2019[2015-16]Status: DisposedITAT Mumbai19 May 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2015-16 Dow Chemical International Private Income Tax Officer-14(1)(3), Limited As Successor Of Rohm & Hass Room No. 458, 4Th Floor, (India) Private Limited, Vs. Aayakar Bhavan, M.K. Road, Godrej It Park-P2, 1St Floor Block B, 02, Mumbai-400020. Lbs Road, Godrej Business District, Pirojshanagar, Vikhroli (West), Mumbai-400079. Pan No. Aaacr 2855 F Appellant Respondent

For Appellant: Mr. Rajan R. Vora/For Respondent: Dr. Yogesh Kamat, CIT-DR
Section 92C

assessee were not functionally comparable with the assessee. The IPO has also commented on the search process and the use of multiple year data. He has dealt with each of the comparable selected by the assessee and has pointed out the defects in them. The TPO has after detailed analysis

Xchanging Solutions Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, grounds 20 to 23 are allowed for statistical purposes

ITA 294/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 May 2022AY 2016-17
For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Dr.Manjunath Karkaihalli, CIT-DR
Section 139(1)Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 40

that allow for introduction of a “range concept” for 18 IT(TP)A No.294/Bang/20201 M/s.Xchanging Solutions Limited determination of ALP and “use of multiple year data” for undertaking comparability analysis in transfer pricing cases. The provisions of the Income-tax Act were amended through the Finance (No.2 ... after PY 2014-15. The amended rules allow for introduction of a “range concept” for determination of ALP and “use of multiple year data” for undertaking comparability analysis in transfer pricing cases. The use of range concept being a statistical tool enhances the reliability of analysis undertaken for computation

Xerox Business Services India Private Limited, Bangalore vs. Asst.C.I.T., Bangalore

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

ITA 361/BANG/2016[2011-12]Status: DisposedITAT Bangalore08 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT-DR
Section 143(3)Section 144Section 144C(5)Section 144C(6)Section 92C

length price and ignoring the provisions of Rule 10B(3) of the Rules, international commentaries and judicial pronouncements, which advocate usage of multiple year data of comparable companies for the purpose of determination of the arm's length price. 17. The learned AO/DRP/TPO erred in law and on facts

Asst.CIT, Bangalore vs. M/S Xerox Business Services of India Pvt. Ltd., Bangalore

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

ITA 202/BANG/2016[2011-12]Status: DisposedITAT Bangalore08 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT-DR
Section 143(3)Section 144Section 144C(5)Section 144C(6)Section 92C

length price and ignoring the provisions of Rule 10B(3) of the Rules, international commentaries and judicial pronouncements, which advocate usage of multiple year data of comparable companies for the purpose of determination of the arm's length price. 17. The learned AO/DRP/TPO erred in law and on facts

M/S Verifone India Technology Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, appeals filed by assessee stands allowed

ITA 3089/BANG/2018[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Verifone India Technology Pvt. Ltd., A 101, 1St Floor, Cyber The Income Tax Park, Plot No. 76, 77 & 78, Officer, Doddathogur Village, Ward – 7 (1) (3), Begur Hobli, Bangalore. Bangalore South Taluk, Vs. Bangalore – 560 100. Pan: Aaccv1683K Appellant Respondent & Assessment Year : 2012-13 M/S. Verifone India Technology Pvt. Ltd., A 101, 1St Floor, Cyber The Deputy Park, Plot No. 76, 77 & 78, Commissioner Of Doddathogur Village, Income Tax, Begur Hobli, Circle – 7 (1)(2), Bangalore South Taluk, Vs. Bangalore. Bangalore – 560 100. Pan: Aaccv1683K Appellant Respondent Assessee By : Shri K.R. Vasudevan, Advocate : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 22-02-2022 Date Of Pronouncement : 25-03-2022

For Appellant: Shri K.R. Vasudevan, Advocate
Section 92C

financial data of the comparable companies while determining the ALP. 5. The learned AO/ learned TPO/ Hon'ble CIT(A) erred in disregarding multiple year data and they ought to have accepted the use of contemporaneous data due to non- availability of current year data in the public domain ... financial data of the comparable companies while determining the ALP. 5. The learned AO/ learned TPO/ Hon'ble CIT(A) erred in disregarding multiple year data and they ought to have accepted the use of contemporaneous data due to non- availability of current year data in the public domain

M/S Verifone India Technology Pvt Ltd, Bangalore vs. Income Tax Officer Ward-7(1)(3), Bangalore

In the result, appeals filed by assessee stands allowed

ITA 3088/BANG/2018[2011-12]Status: DisposedITAT Bangalore25 Mar 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Verifone India Technology Pvt. Ltd., A 101, 1St Floor, Cyber The Income Tax Park, Plot No. 76, 77 & 78, Officer, Doddathogur Village, Ward – 7 (1) (3), Begur Hobli, Bangalore. Bangalore South Taluk, Vs. Bangalore – 560 100. Pan: Aaccv1683K Appellant Respondent & Assessment Year : 2012-13 M/S. Verifone India Technology Pvt. Ltd., A 101, 1St Floor, Cyber The Deputy Park, Plot No. 76, 77 & 78, Commissioner Of Doddathogur Village, Income Tax, Begur Hobli, Circle – 7 (1)(2), Bangalore South Taluk, Vs. Bangalore. Bangalore – 560 100. Pan: Aaccv1683K Appellant Respondent Assessee By : Shri K.R. Vasudevan, Advocate : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 22-02-2022 Date Of Pronouncement : 25-03-2022

For Appellant: Shri K.R. Vasudevan, Advocate
Section 92C

financial data of the comparable companies while determining the ALP. 5. The learned AO/ learned TPO/ Hon'ble CIT(A) erred in disregarding multiple year data and they ought to have accepted the use of contemporaneous data due to non- availability of current year data in the public domain ... financial data of the comparable companies while determining the ALP. 5. The learned AO/ learned TPO/ Hon'ble CIT(A) erred in disregarding multiple year data and they ought to have accepted the use of contemporaneous data due to non- availability of current year data in the public domain

Dhl Logistics P.Ltd, Mumbai vs. DCIT Cir 9(3)(1), Mumbai

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

ITA 7286/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Mar 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadaledhl Logistics Pvt Ltd Vs. Acit – 9(3)(1) 201A, Silver Utopia, Room No. 215, Cardinal Gracias Road 2Nd Floor, Aayakar Chakala, Andheri (E) Bhavan, M.K.Road, Mumbai – 400099 Mumbai – 400020 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm6824A Appellant .. Respondent Appellant By : Shri. Madhur Agarwal.Ar Respondent By : Dr. Yogesh Kamat.Cit.Dr Date Of Hearing 27.01.2022 Date Of Pronouncement 15.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Shri. Madhur Agarwal.ARFor Respondent: Dr. Yogesh Kamat.CIT.DR
Section 143(3)Section 144C(5)Section 92D

adjustment to the extent of the value of the international transaction undertaken by the assessee. 2.5- not allowing the use of multiple year data as prescribed under Rule 1013(4) of the Rules read with the OECD TP Guidelines, and determining the arm's length price on the basis

M/S Brady Company India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(4), Bangalore

In the result, ground 26 is allowed for statistical purposes

ITA 790/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.103/Bang/2019 : Asst.Year 2014-2015 It(Tp)A No.790/Bang/2019 : Asst.Year 2014-2015 M/S.Brady Company India Private The Income Tax Officer Limited, No.26, Survey No.41 Ward 1(1)(4) V. Bengaluru. Konappana Agrahara Village Begur, Hobli, Electronci City, Phase-Ii, Bengaluru – 560 100. Pan : Aaccb8163A (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 22.03.2022 Date Of Hearing : 07.03.2022 O R D E R Per George George K, Jm : These Appeals Are At The Instance Of The Assessee. The Relevant Assessment Year Is 2014-2015. 2. The Reason For Filing Two Appeals For Assessment Year 2014-2015 Is That Pursuant To The Dispute Resolution Panel’S (Drp) Directions (Directions Dated 28.09.2008), The A.O. Passed Final Assessment Order U/S 143(3) R.W.S. 144C Of The I.T.Act Dated 15.11.2018. In The Said Assessment Order, The Aggregate Transfer Pricing Adjustment Was Determined At Rs.14,43,51,081. An Appeal Has Been Filed Before The Tribunal Against The Order U/S 143(3) R.W.S. 144C Of The I.T.Act (Appeal No.It(Tp)A No.103/Bang/2019). Subsequently, On Application By The Assessee, The Drp Passed Rectification Order Dated

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 154

para 6.2 of TP order). The TPO rejected the comparables set taken by the assessee for the reason that the assessee had considered multiple year data. The TPO conducted a fresh TP analysis and selected a set of 26 comparable companies, which contained 16 comparables selected by the assessee

M/S Brady Company India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(4), Bangalore

In the result, ground 26 is allowed for statistical purposes

ITA 103/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.103/Bang/2019 : Asst.Year 2014-2015 It(Tp)A No.790/Bang/2019 : Asst.Year 2014-2015 M/S.Brady Company India Private The Income Tax Officer Limited, No.26, Survey No.41 Ward 1(1)(4) V. Bengaluru. Konappana Agrahara Village Begur, Hobli, Electronci City, Phase-Ii, Bengaluru – 560 100. Pan : Aaccb8163A (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 22.03.2022 Date Of Hearing : 07.03.2022 O R D E R Per George George K, Jm : These Appeals Are At The Instance Of The Assessee. The Relevant Assessment Year Is 2014-2015. 2. The Reason For Filing Two Appeals For Assessment Year 2014-2015 Is That Pursuant To The Dispute Resolution Panel’S (Drp) Directions (Directions Dated 28.09.2008), The A.O. Passed Final Assessment Order U/S 143(3) R.W.S. 144C Of The I.T.Act Dated 15.11.2018. In The Said Assessment Order, The Aggregate Transfer Pricing Adjustment Was Determined At Rs.14,43,51,081. An Appeal Has Been Filed Before The Tribunal Against The Order U/S 143(3) R.W.S. 144C Of The I.T.Act (Appeal No.It(Tp)A No.103/Bang/2019). Subsequently, On Application By The Assessee, The Drp Passed Rectification Order Dated

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 154

para 6.2 of TP order). The TPO rejected the comparables set taken by the assessee for the reason that the assessee had considered multiple year data. The TPO conducted a fresh TP analysis and selected a set of 26 comparable companies, which contained 16 comparables selected by the assessee

Addl/Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Texas Instruments (India) Pvt Ltd, Bangalore

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

ITA 525/BANG/2019[2011-12]Status: FixedITAT Bangalore11 Mar 2022AY 2011-12

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115Section 115QSection 143(3)Section 246A

objection with regard to selection of a comparable. At the time of preparing T.P. Study report assessee had selected some comparables by considering multiple year data and information available at the relevant time. However, if subsequently on the basis of information available in public domain it is found

M/S Texas Instruments (India) Pvt Ltd, Bangalore vs. Joint Commissioner of Income Tax Ltu, Bangalore

In the result, the appeal filed by the assessee is partly allowed and appeal of the revenue is dismissed

ITA 275/BANG/2019[2011-12]Status: FixedITAT Bangalore11 Mar 2022AY 2011-12

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 115Section 115QSection 143(3)Section 246A

objection with regard to selection of a comparable. At the time of preparing T.P. Study report assessee had selected some comparables by considering multiple year data and information available at the relevant time. However, if subsequently on the basis of information available in public domain it is found