HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

Capital Gains Accounts Scheme as mandated under IT(IT)A No.258/Bang/2025 HanchipuraChannaiah Nandakishore, Bangalore Page 4 of 16 section 54(2) of the Act. 5 The construction has not been completed within three years period i.e. within 31/07/2018. 3.3 The AO accordingly assessed the LTCG at Rs. 26,91,120/-. The AO passed the assessment order u/s 147 r.w.s. 144C

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

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

144C gives a complete go bye to section 153; and (ii) The Act does not contemplate any limitation for passing of draft assessment order, which can be passed within a reasonable time. 14. Though arguments were advanced that the aforesaid decision does not lay down the correct law, we are of the view that a co-ordinate Bench decision

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

Capital Gain u/s.45 of the Act. 4. Aggrieved by the assessment completed u/s. 147 r.w.s. 144C(13) of the Act dated 12.12.2024, the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paper book in support of his case. 5. Before us, the ld. A.R. of the assessee vehemently submitted that the assessee

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

4. Grounds on section 144C: i. The learned assessing officer is not justified in treating the appellant as an ‘eligible assessee’ in terms of section 144C of the Act for the relevant assessment year on the facts and circumstances of the case. ii. Without prejudice, the impugned order passed under section 147r.w.s144C of the Act is barred by limitation

M/S INATECH INDIA PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-3(1)(4), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2012-13

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

gain of the Company should be treated as an operating income for the purpose of the transfer pricing analysis. III. Carrying out erroneous working capital adjustment while undertaking the transfer pricing analysis. IV. Erroneously considering the segmental results of AE and Non AE operations while proposing the transfer pricing adjustment. IT(TP)A No. 214/Bang/2018 Page 7 of 23 Erroneously

RAVIKUMAR TIRUPATI PARTHASARATHY,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), BANGALORE

In the result, the appeal is allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2019-20

section 144C of the Act, the AO completed the assessment u/s. 143(3) r.w.s. 144C by issuing a draft assessment order in which an addition of Rs.52,89,346 was made towards capital gains. Aggrieved, the assessee filed its objections before the DRP, who confirmed the said addition. The AO in the final assessment order considered the correct indexation value

FIDELITY BUSINESS SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

144C of the Act. 6 That on the facts and in the circumstances of the case and in law, the learned AO erred in holding that interest under section 115-P of the Act is leviable on the Appellant. 7 That the Appellant craves leave to add to and / or to alter, amend, rescind, modify, the grounds herein above

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

capital asset. Respectfully following the same, we direct the disallowance to be deleted. 13. Ground No.26: Disallowance of Commission paid Rs.23,68,35,533/- 13.1. The Ld.AR submitted that, the assessee generates substantial part of its business from overseas clients, mainly from the North American, European and Asia Pacific markets. It is submitted that, in order to procure new business

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

144C(13) of the Income- tax Act,1961 ['the Act' for short] in pursuance of directions issued by Ld Dispute Resolution Panel (DRP). The assessee has filed the appeals for assessment years 2009-10 to 2014-15. The revenue has filed the appeals for assessment years 2009-10 to 2011-12. Since most of the issues urged in these appeals

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

144C(13) of the Income- tax Act,1961 ['the Act' for short] in pursuance of directions issued by Ld Dispute Resolution Panel (DRP). The assessee has filed the appeals for assessment years 2009-10 to 2014-15. The revenue has filed the appeals for assessment years 2009-10 to 2011-12. Since most of the issues urged in these appeals

M/S DELL INTERNATIONAL SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal is allowed

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

144C of the Act and therefore the AO passed the final assessment order dated 21.2.2011 incorporating the additions suggested by the TPO in his order. Against the said order of assessment, the Assessee preferred appeal before the CIT(A), who confirmed the order of the AO. Hence this appeal by the Assessee before the Tribunal

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

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

4. The foundation of the action of the authorities below for the denial of deduction is premised on the understanding that the modified return cannot breach the mandate of the APA, which, in turn, restricts its scope only to the determination of the ALP and nothing more than that. 5. In order to appreciate the rival contentions, it would

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

capital gain income of Rs. 37,28,537/- on sale of sale of equity share / unit of equity oriented Mutual Fund under section 111A. 3.2 Subsequent to a survey conducted under section 133A, proceedings under section 147 of the Act were initiated accordingly notice under section 148 of the Act dated 25.03.2021 was issued, requiring the Assessee to file

M/S.ASM TECHNOLOGIES LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(2), BANGALORE

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

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.66/Bang/2017 Assessment Year : 2012-13 M/S. Asm Technologies Ltd., Vs. Dcit, No.80/2, Lusanne Court, Circle – 1(1)(2), Richmond Road, Bengaluru. Bengaluru – 560 025. Pan : Aabca 4362 P Appellant Respondent Assessee By : Shri. Suresh Muthukrishnan, Ca Revenue By : Ms. Neera Malhotra, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 23.06.2021 Date Of Pronouncement : 30.06.2021 O R D E R Per N. V. Vasudevan

Capital Adjustment (As per Annex. C) Adjusted margin 23.06% 61,22,85,229 Operating Cost (in Rs.) 75,34,76,203 Arm's Length Price(ALP) (in Its.) 123.06% of Operating Cost) Price Received (in Rs.) 71,14,17,247 4,20,60,956 Variation between the ALP and price received (in Rs.) 3,55,70,862 5% of price

RANGARAJ ROHINI,INDIRANAGAR BANGALORE vs. DEPUTY COMMSSIONER OF INCOME TAX ASMNT CIRCLE 2(1) BANGALORE, KORMANGALA BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

section 143(3)/ 144C(13) for the assessment year 2022-23. 2. The necessary facts are that the assessee in the present case is an individual and filed her Income Tax Return for AY 2022-23 on 16.05.2022, declaring total income at Rs. 64,86,380/- only. The assessee declared her residential status as "Non-Resident." The assessee reported

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

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

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

Gains from Business' after claim of deduction under section 1 OA for the Bangalore and Pune units., the learned AO be directed to allow carry forward of the loss under the head 'Income from other Sources' amounting to Rs. 2, 16,017 for set off against income in subsequent years. 3. Interest under section 234B The learned AO has erred

ASST. CIT, BANGALORE vs. M/S CGI INFORMATION SYSTEMS & MANAGEMENT CONSULTANT PVT. LTD.,, BANGALORE

In the result, the revenue’s appeal is dismissed and the

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Rao

4. Larsen & Toubro Infotech Ltd., 19.33 19.43 5. Mindtree Ltd., (Seg) 14.83 12.74 6. Persistent Systems & Solutions 15.38 15.15 Ltd., 7. Persistent systems Ltd., 30.35 28.11 8. R S Software (India) Ltd., 10.29 10.45 9. Sasken Communication 17.36 16.41 Technologies Ltd., 10. Tata Elxsi Ltd., (Seg) 20.93 17.20 11. Thinksoft Global Services Ltd., 17.05 13.96 AVERAGE MARGIN

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

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

144C of the Income Tax Act, 1961 (the Act). The relevant M/s. Palmer Investment Group Ltd. assessment year is 2014-15. Common issues are raised in these appeals, hence they were heard together and are being disposed off by this consolidated order. 2. Facts pertaining to both the assessees are identical except for variation in figures. Therefore we are setting

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

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

144C of the Income Tax Act, 1961 (the Act). The relevant M/s. Palmer Investment Group Ltd. assessment year is 2014-15. Common issues are raised in these appeals, hence they were heard together and are being disposed off by this consolidated order. 2. Facts pertaining to both the assessees are identical except for variation in figures. Therefore we are setting