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

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)

condonation of delay in e-verification of the return. 3.9 The Assessee filed its objections with the Dispute Resolution Panel ('DRP') in Form 35A, as per section 144C(2) of the Act on 28.04.2023. The DRP issued its directions on 22.12.2023. Some issues were partially decided in favor of the Assessee. 3.10 Post receipt

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

5 IT(TP)A No.1277/Bang/2011 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

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

delay of 7 days in filing the appeal and condone the same. 3. As far as merits of the appeal of the assessee is concerned, the preliminary point that needs to be decided is ground No.2 raised by the assessee in its appeal which reads as follows:- “Further, based on the facts and circumstances of the present case

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

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

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)

144C (13) of the Act. , Subsequently, the matter travelled to ITAT and the Assessing Officer has passed the order giving effect dt.18.12.2017 giving effect to ITAT order. Whereas assesses filed rectification petition u/sec154 of the Act against the said order. Subsequently, The assessee has filed an appeal against the order under Section 154 of the Act dt.24.04.2018. The CIT(Appeals

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

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. 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

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

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

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

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

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

M/S. GE BE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Shri George K. George

144C(5) of the Income-tax Act,1961 ['the Act' for short] consequent to the direction of Ld. Dispute Resolution Panel (“DRP”) dated 3.9.2019. The assessee has raised followings grounds of appeal:- Grounds:- IT(TP)A No.2615/Bang/2019 M/s. GE BE Pvt. Ltd., Bangalore Page 2 of 24 The grounds mentioned herein by the Appellant are without prejudice to one another

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