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 this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. 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 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

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 this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. 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 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

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 this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. 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 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

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 this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. 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 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

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 this inordinate delay of 1694 days and the appeal is dismissed unadmitted. Accordingly, we decline to admit the appeal and dismiss the appeal in limine. 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 7 of 34 ITA No.468/Bang/2015 (A.Y. 2010-11) (Assessee’s appeal):- 4. Grounds urged

MRS. SUVINA KRUPAL,SOMWARPET vs. ITO, MADIKERI

In the result appeal stands allowed as indicated hereinabove

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

condonation of delay in filing present appeal stands allowed. Brief facts of the case are as under: 5. Assessee is a company and filed its return of income for year under consideration on 31/10/2005 declaring nil income. The return was processed under section 143 (1) of the act and Page 6 of 28 ITA No.337 & 204/Bang/2014 the case was subsequently

JCIT vs. M/S DELL INTERNATIONAL SERVICES INDIA,

In the result, IT(TP)A No

Bench: Shri N.V.Vasudevan & Shri Jason P. Boaz

92B(1) or the Act to mean a transaction between two or more "associated enterprises" either or both of whom are non-residents in IT(TP)A Nos. 85 & 1026/B/14, 1838/B/13 & CO No.21/B/16 Page 16 of 36 the nature of inter alia purchase, sale or lease of intangible property or provision of services, or lending or borrowing money

JCIT, BANGALORE vs. M/ SDELL INTERNATIONAL SERVICES INDIA (P) LTD.,, BANGALORE

In the result, IT(TP)A No

Bench: Shri N.V.Vasudevan & Shri Jason P. Boaz

92B(1) or the Act to mean a transaction between two or more "associated enterprises" either or both of whom are non-residents in IT(TP)A Nos. 85 & 1026/B/14, 1838/B/13 & CO No.21/B/16 Page 16 of 36 the nature of inter alia purchase, sale or lease of intangible property or provision of services, or lending or borrowing money

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

92B. The mechanism u/s. 92CA triggers when a reference is made by the Ld.AO under 92CA(1) of the act.\n6.10 It is categorically noted that the reference is to be made during the course of assessment proceedings before the expiry of the period to pass an assessment order u/s. 153 of the act which means that there

ASST.C.I.T., BANGALORE vs. M/S ALCON LABORATORIES (INDIA) PVT. LTD.,, BANGALORE

In the result, both the appeal by the revenue and cross objection by the assessee are partly allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

92B(1) of the Act, the transaction of providing SWD Services and MSS were “international transactions” i.e., a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having