KIRLOSKAR TOYOTA TEXTILE MACHINERY PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE

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

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

92D of the Act. 4. That the Learned AO in pursuance of the directions issued by the Hon'ble Panel erred in law and facts by rejecting the economic analysis undertaken by the Appellant in accordance with the provisions of the Act and the Income-tax Rules, 1962 (`the Rules'), thereby arbitrarily rejecting the economic analysis undertaken by the Appellant

M/S. SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 6, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

92D of the Act, in good faith and with due diligence. 4.2. Rejecting the comparability analysis carried out by the Appellant in the TP documentation and in conducting a fresh comparability analysis for the software development services based on the application of additional filters in determining the arm's length price. 4.3. Using data, which was not contemporaneous and which

M/S. PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal by the assessee is allowed

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

Section 92D of the Act, in good faith and with due diligence; 6.2. Rejecting the filters selected by the Appellant as captured in the TP documentation and adopting certain addition filters which are not in accordance with the jurisprudence laid down by various appellate forums; 6.3. Application of related party transaction (‘RPT’) filter by applying an inappropriate interpretation of computing

ATOS IT SERVICES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

92D of the Act, in good faith and with due diligence; 2.3. Rejecting the comparability analysis carried out by the Appellant in the TP documentation and conducting a fresh comparability analysis for software development services based on application of addition filters/ modified filters in determining the arm's length price; 2.4. Disregarding certain filters applied by the Appellant

LENOVO (INDIA) PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD- 4(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for above terms

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

capital adjustment) while calculating the arm’s length margin for final set of comparable companies under the TNMM for the manufacturing segment. III. TP adjustment of INR 125,54,51,517 on account of alleged excess AMP expenditure pertaining to trading segment: 14. The Honourable DRP and the learned AO / TPO have erred in law and on facts, in making