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

section 144C of the Act. The assessee remained under the impression that the appeal was still pending before the NFAC. It was only during a routine review of pending appeals for the statutory audit that the assessee discovered that the NFAC had dismissed the appeal under the wrong assumption of facts that it was settled under the VSV scheme

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

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, 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

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

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.

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 and also an affidavit stating therein the reasons for belated filing of this appeal. On perusal of the reasons

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.

delayed receivable of Rs.20,68,559 was reduced to Rs.10,62,815. Thus as per the order giving effect to the direction of the DRP u/s. 144C dated 10.7.2024, the TP adjustment to the extent of Rs.10,62,815 was retained. So far as Transfer pricing issues are concerned, in Final assessment order Transfer pricing adjustment of Rs.10