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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

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

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 of 22 days on the part of the assessee in filing the objections before the DRP. We accordingly set aside the order of the DRP under Section 144C(5) of the Act dt.4.10.2016, as well as the impugned order of assessment for Assessment Year 2012-13 dt.8.11.2016, and restore the matter of examination and adjudication

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

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

1) for the assessment year 2010-11. Page 2 of 7 2. First, it is noted that there is a delay of 1206 days in filing the appeal before the ITAT. The assessee has submitted a duly notarized condonation petition explaining the delay. In the petition, the assessee stated that for the year under consideration, two appeals were filed before

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 of the Income Tax Act, 1961 (in short 'the Act') vide order dt.23.9.2011

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)

1) of the Act along with questionnaire were issued. The Assessing Officer found that the assessee has Transfer Pricing Adjustments and also made disallowance of interest on delayed payment of TDS/TCS under the head Misc. expenses, tools writtenoff and assessed the total income of (-) Rs.3,83,70,245 and passed the order under Section 143(3) r.w.s. 144C

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

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 :

1) of the Income-tax Act, 1961 [hereinafter referred to as 'the Act' for short] the case was selected for scrutiny by issuing requisite notice u/s 143(2) of the Act. During the course of scrutiny proceedings, the Assessing Officer (AO) noticed that the assessee-company shown international transactions with its Associated Enterprises (AEs). Therefore, he referred the matter

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

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. ENZEN GLOBAL SOLUTIONS PVT LTD , BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K

condone the delay and proceed to adjudicate the issue on merit. 6. We, first, take up appeal No.696/Bang/2024 for the assessment year 2017-18 7. The grounds raised in ITA No.696/Bang/2023 is reproduced as under:- “1. The Ld. CIT(A) erred in law in deleting the addition of Rs. 21,45,00,000/- made towards premium on preference shares