M/S CONERGY ENERGY SYSTEMS PRIVATE LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result, the assessee's appeal for Assessment Year 2012-13 is allowed for statistical purposes

Bench: Shri Jason P Boaz & Shri Laliet Kumar

condone the delay beyond the period specified for filing of objections under Section 144C(2) of the Act. Therefore the assessee

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)

144C(1) of the Act on 30.03.2023, determining the total income of the Assessee at Rs. 340,68,58,962 after incorporating the TP adjustments as above and making certain disallowances under section 14A and section 37 of the Act. It may be noted that the draft assessment order was passed post the date of condonation of delay

SCHNEIDER ELECTRIC IT BUSINESS INDIA PRIVATE LIMITED(FORMERLY KNOWN AS AMERICAN POWER CONVERSION (INDIA) PVT LTD.),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS, , BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2010-11

condonation petition explaining the delay. In the petition, the assessee stated that for the year under consideration, two appeals were filed before the NFAC, as detailed below: 3. The assessee opted for the VSV scheme to settle the dispute related to the order passed under section 143(3) read with Section 263 of the Act. However, the NFAC mistakenly dismissed

FLOWSERVE INDIA CONTROLS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2007-08 is partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

condone the delay in filing this appeal before the Tribunal and admit the appeal for consideration and adjudication. It is ordered accordingly. O R D E R This appeal by the assessee is directed against the final order of assessment passed under Section 143(3) r.w.s. 144C

WALVOIL FLUID POWER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, TRANSFER PRICING - 2(2)(2), BANGALORE

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

Bench: Shri A.K. Garodia & Sri Pavankumar Gadaleit(Tp)A No.1620/Bang/2019 (Assessment Year: 2009-10) M/S. Walvoil Fluid Power India Pvt. Vs. Dy. Commissioner Of Ltd., Income Tax, No.19, 2Nd Cross, 2Nd Main, Kiadb, Transfer Pricing 2(2)(2), Attibele Indl. Area, Attibele, Anekal Bangalore. Taluk, Bangalore-562107 Pan: Aaacw 5954E (Appellant) (Respondent)

condoned. 3. The Brief facts of the case are that the assessee is engaged in the manufacture of control valves and filed the Return of Income on 29.09.2009 with total income of (-) Rs.7,36,89,967. Subsequently, the case was selected for scrutiny and Notice under Section 143(2) and 142(1) of the Act along with questionnaire were issued

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

condone the delay of 1694 days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section 154 of the Act dated

FLEXTRONICS TECHNOLOGIES (INDIA) PRIVATE LIMITED ,TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Inturi Rama Rao

144C(13) of the Income Tax Act, 1961 [“the Act”] by the ACIT, Circle 3(1)(1), Bangalore in relation to assessment year 2012-13. IT(TP)A No.832/Bang/2017 Page 2 of 8 2. There is a delay of 7 days in filing the appeal by the assessee which has been explained as owing to the absence of the Managing

RAICHUR CITY URBAN CO-OPERATIVE BANK LTD.,,RAICHUR vs. DIT, BANGALORE

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

Bench: Shri Inturi Rama Raoshri Laliet Kumarraichur City Urban Co-Operative Bank Ltd., Gunj Road, Raichur-584 102. . Appellant Vs. The Dy. Director Of Income-Tax Intelligence & Criminal Investigation, Bengaluru. . Respondent Appellant By : Shri B.S Sudheendra, C.A Respondent By : Shri G Kamaladar, Standing Counsel

144C.] ITA No.1147/ /B/15 [(4) The Assessing Officer or the assessee, as the case may be, on receipt of notice that an appeal against the order of the Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals) or the Assessing Officer in pursuance of the directions of the Dispute Resolution Panel has been preferred under sub-section

M/S. CRYSTAL GRANITE AND MARBLE PRIVATE LIMITED,RAMANAGARAM vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes and Stay Petition is dismissed as infructuous

Bench: Shri George George K & Shri Laxmi Prasad Sahus.P No.29/Bang/2023 Assessment Year: 2017-18

144C of the Income-tax Act or issuance of notice under section 148 as per time-limit specified in section 149 or sanction under section 151 of the Income-tax Act, and the time limit for completion of such action expires on the 30th day of April, 2021 due to its extension by the said notifications, such time limit shall

ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-4(1)(1), BANGALORE, BANGALORE vs. MANHATTAN ASSOCIATES (INDIA) DEVELOPMENT CENTRE PRIVATE LIMITED, BANGALORE

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year: 2011-12 Acit, Vs. M/S. Manhattan Associates (India) Circle – 4(1)(1), Development Centre Pvt. Ltd., Bangalore. 5Th & 6Th Floor, B1 Block, Brigade Tech Gardens Brigade Properties Pvt. Ltd., Sez, Brookfield, Kundalahalli S.O. Bangalore North, Bangalore – 566 037. Pan: Aadcm 0727 A Appellant Respondent Appellant By : Shri. Nirmal Mathew, Advocate Respondent : Dr. Divya K. J, Cit(Dr)(Itat), By Bangalore. Date Of Hearing : 02.02.2026 Date Of Pronouncement : 10.03.2026

144C of The Income Tax Act, 1961[ The ACT] .The assessing officer, expressing dissatisfaction with the appellate order has submitted this appeal, outlining nine separate grounds related to transfer pricing matters. 2. According to Form No. 36 under Rule 47(1) of the Income Tax Rules 1962, the learned AO noted that the order issued under Section

NMS COMMUNICATIONS P. LTD. vs. DCIT,

In the result, appeal is treated as allowed for statistical purposes

Bench: Shri B. Ramakotaiah & Shri Narendra Kumar Choudhury

144C of the Act dt. 24th December, 2010 with the following adjustments: Rs. Total income as returned by assessee 7,000 Add: Adjustments: 1. Transfer Pricing adjustment 1,11,77,183 2. Denial of tax holiday u/s. 10A of the Act on account of non-production of FIRCs and 2,35,83,305 reduction in tax holiday on account

ASST.C.I.T., BANGALORE vs. M/S MILLIPORE (INDIA) LTD.,, BANGALORE

In the result, the cross objections are partly allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raoit(Tp)A No.327/Bang/2015 (Assessment Year: 2009-10) Asst. Commissioner Of Income-Tax, Circle 4(1)(2), Bengaluru. … Appellant Vs M/S.Millipore (India) Ltd. No.50A, 2Nd Phase, Peenya Industrial Area, Bengaluru-560058. … Respondent Pan:Aaccm 1226 B & Co No.188/Bang/2015 (In It(Tp)A No.327/Bang/2015) (Assessment Year: 2009-10) (By The Assessee) Revenue By : Smt. Swapna Das, Jcit Assessee By : Shri K.K. Chaythanya, Advocate Date Of Hearing : 06/12/2016 Date Of Pronouncement : 07/03/2017 O R D E R Per Inturi Rama Rao, Am :

section 92CA of the Act. The final assessment order u/s 143(3) r.w.s. 144C of the Act was passed by the AO on 26/05/2013. 3. Aggrieved by the above disallowances, the assessee- company preferred an appeal before the CIT(A) who, vide impugned order allowed the appeal in respect of issues on apportionment of interest on working capital, factory overheads