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

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 the NFAC, as detailed below: 3. The assessee opted

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

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), 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. 2

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. 2

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

MS. PUSPHA RAO PAMIDI,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahums. Pushpa Rao Pamidi Vs Dcit, Circle - 2(1) No. 156/1, C/O T. Viswanath & Co Bengaluru Sharada Mansion, 2Nd Floor R V Road, V V Puram Bengaluru 560004 Pan – Bhhpp1695K (Appellant) (Respondent) Assessee By: Shri Sathish S., Advocate Revenue By: Ms. Neera Malhotra, Cit-Dr Date Of Hearing: 07.02.2023 Date Of Pronouncement: 08.02.2023 O R D E R Per: George George K., J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Final Assessment Order Dated 28.07.2022 Passed Under Section 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (The Act). The Relevant Assessment Year Is 2018-19. 2. There Is A Delay Of Four Days In Filing This Appeal Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay & Also An Affidavit Stating Therein The Reasons For Belated Filing Of This Appeal. On Perusal Of The Reasons Stated In The Affidavit We Find That The Delay In Filing The Appeal Cannot Be Attributed To Any Latches On The Part Of The Assessee & There Is Sufficient Cause For Belated Filing Of This Appeal. Hence, We Condone The Delay Of Four Days & Proceed To Dispose Of The Case On Merits.

Section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (the Act). The relevant assessment year is 2018-19. 2. There is a delay of four days in filing this appeal before the Tribunal. The assessee has filed a petition for condonation

TE CONNECTIVITY SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. DCIT CIRCLE, 7(1)(1), , BANGALORE

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

2) of the Act, which was approved by the PCIT and thereafter the TPO passed an order u/s. 92CA(3) of the Act on 11.5.2023 proposing an adjustment of Rs.7,95,56,559. 5. Subsequently a draft order was passed on 12.9.2023 which was objected before the ld. DRP. The ld. DRP passed its directions. Based IT(TP)A No.1887/Bang/2024