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11 results for “condonation of delay”+ Section 92Cclear

Sorted by relevance

Kolkata28Mumbai18Delhi16Bangalore11Chennai11Pune7Hyderabad6Ahmedabad5Karnataka2Nagpur1Calcutta1

Key Topics

Section 10A25Section 143(3)10Section 92C7Transfer Pricing6Section 1475Addition to Income5Section 1444Section 14A4Deduction4

ACIT, BANGALORE vs. M/S. SYNOVA INNOVATIVE TECHNOLOGIES PVT.LTD, BANGALORE

The appeal of the revenue stands partly allowed in

ITA 36/BANG/2011[2004-05]Status: DisposedITAT Bangalore23 Dec 2016AY 2004-05

Bench: Shri S.K.Yadav & Shri A. K. Garodia

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri Sanjay Kumar, CIT-III
Section 92C(2)

condonation of delay as per para-9 & 10 of the affidavit, as reproduced below; “9. In this regard, your cross objector wishes to submit that the Finance Act 2012, has amended provisions of sec.92C of the Act, by inserting sub-sections 2A and 2B. 9 IT(TP)A Nos.36 & 37(B)/2011 & C.O. No.219(B)/2015 Newly inserted section 92C

DCIT, BANGALORE vs. M/S FMC INDIA PVT. LTD.,, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2007-08 is partly allowed and the assessee's C

Condonation of Delay4
Section 143(2)3
Section 92C(2)3
ITA 431/BANG/2012[2007-08]Status: Disposed
ITAT Bangalore
10 Apr 2015
AY 2007-08
For Respondent: Dr. P.K. Srihari, Addl. CIT (D.R)
Section 143(1)Section 143(3)Section 92C

Section 92C(2) of the Act. Thus, as per the above amendment, it is clear that the +/- 5% variation is only to justify the price charged for international transactions and not for adjustment purposes. The aforesaid amendment brought about by Finance Act, 2012 has settled the issue and accordingly the 5% standard deduction benefit is not allowable to assessees

DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE-4(1)(1), BANGALORE, BANGALORE vs. EYGBS (INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeal by the AO is dismissed

ITA 1586/BANG/2024[2017-18]Status: DisposedITAT Bangalore19 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 92C(4)

section 92C(4) is not applicable and assessee is entitled to higher deduction. The ld. AO considered the explanation of the assessee and held that assessee is not eligible to deduction u/s. 10AA of the Act on Page 3 of 7 the above adjustment, pursuant to APA and accordingly excess claim of deduction u/s. 10AA of Rs.6

FLOWSERVE INDIA CONTROLS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2007-08 is partly allowed

ITA 1277/BANG/2011[2007-08]Status: DisposedITAT Bangalore02 May 2018AY 2007-08

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT (D.R)
Section 143(1)Section 143(3)Section 144CSection 92C

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

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

ITA 311/BANG/2024[AY 2015-16]Status: DisposedITAT Bangalore20 Feb 2025

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

For Appellant: Sri Padam Chand Khincha, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(2)Section 144Section 144C(10)Section 144C(5)Section 147Section 148Section 153

92C(3) of the Act and not accepting the TP documentation/economic analysis which was undertaken by the Appellant in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (‘the Rules’) and conducting a fresh economic analysis for the determination of the arm’s length price of the impugned international transactions. On the facts and circumstances

MRS. SUVINA KRUPAL,SOMWARPET vs. ITO, MADIKERI

In the result appeal stands allowed as indicated hereinabove

ITA 337/BANG/2014[2004-05]Status: DisposedITAT Bangalore14 Aug 2020AY 2004-05

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

For Appellant: Shri L Barath, C.AFor Respondent: Shri Manjeet Singh, Addl. CIT – DR
Section 92C

92C of the Act contending that the information or data used in the computation of the arms length price is not reliable or correct. In doing so: 3(a) the learned CIT(A) erred in rejecting the set of filters applied by the appellant in the TP documentation and in introducing additional filters for selection/ rejection of companies as comparable

NMS COMMUNICATIONS P. LTD. vs. DCIT,

In the result, appeal is treated as allowed for statistical purposes

ITA 1541/BANG/2012[2007-08]Status: DisposedITAT Bangalore18 Mar 2016AY 2007-08

Bench: Shri B. Ramakotaiah & Shri Narendra Kumar Choudhury

For Appellant: Shri Mahavir C. Jain, CAFor Respondent: Ms. Neera Malhotra, CIT
Section 10ASection 143(3)Section 144C

delay in filing the appeal is condoned and appeal is admitted. IT(TP)A No. 1541/Bang/2012 Page 4 of 9 Corporate matters: 4. Ground No. 2 raised by assessee is on denial of deduction u/s. 10A on the ground of non-production of export invoices. At the draft assessment order stage, AO denied the deduction u/s. 10A on the reason

M/S SAINT -GOBAIN INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

In the result, assessee’s appeal is partly allowed for statistical purposes

ITA 2295/BANG/2018[2013-14]Status: DisposedITAT Bangalore15 Apr 2019AY 2013-14

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleita. No.2295/Bang/2018 Assessment Year: 2013-14 Saint-Gobain India Private Vs. Dcit, Limited Circle-6(1)(1), (For The Merged Entity Saint-Gobain Bmtc Building, 80 Feet Crystals & Detectors India Limited) Road, 6Th Block, 171/2, Maruthi Indl. Estate Koramangala, Hoodi Rajapalya, Whitefield Bangalore – 560095. Main Road, Bangalore – 560001. Pan: Aaacb 6794 R (Appellant) (Respondent) For Assessee: Shri Sharatha Rao For Revenue : Smt Renuga Devi, Jcit Date Of Hearing : 09.04.2019 Date Of Pronouncement : 15.04.2019 Order Per Pavan Kumar Gadale, Jm. The Assessee Has Filed An Appeal Against The Order Of The Cit (A)-6, Bangalore, Dated 31/01/2018 Passed U/S 143(3) & U/S 250 Of The It Act, 1961 For The Assessment Year 2013-14. 2. At The Outset, We Notice That There Is A Delay Of 65 Days In Filing The Appeal Before The Tribunal. Ld Ar Drawn Our Attention To The Affidavit Filed By The Assessee, Explaining The Reasons For Not Filing The Appeal

For Appellant: Shri Sharatha RaoFor Respondent: Smt Renuga Devi, JCIT
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 244ASection 250

condone the delay of 65 days and admit the appeal of the assessee. 4. At the time of hearing, Ld AR has not pressed the Grounds of Appeal “B” in respect of income corresponding to TDS appearing in Form 26AS and made endorsement in the appeal memo. Accordingly, the said Ground “B” is treated as not pressed and dismissed

JCIT vs. M/S DELL INTERNATIONAL SERVICES INDIA,

In the result, IT(TP)A No

ITA 1838/BANG/2013[2005-06]Status: DisposedITAT Bangalore13 Oct 2017AY 2005-06

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

For Appellant: Shri K.R. Vasudevan, Advocate &For Respondent: Ms. Neera Malhotra, CIT(DR), ITAT, Bengaluru
Section 10ASection 143(3)Section 147

Section 92C(1) of the Act provides that the arm's length price in relation to an international transaction shall be determined by any of the several methods, specified therein, having regard to the nature of the transaction or class of transaction or class of associated person or functions performed by such persons or such other relevant factors

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

In the result, IT(TP)A No

ITA 1026/BANG/2014[2005-06]Status: DisposedITAT Bangalore13 Oct 2017AY 2005-06

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

For Appellant: Shri K.R. Vasudevan, Advocate &For Respondent: Ms. Neera Malhotra, CIT(DR), ITAT, Bengaluru
Section 10ASection 143(3)Section 147

Section 92C(1) of the Act provides that the arm's length price in relation to an international transaction shall be determined by any of the several methods, specified therein, having regard to the nature of the transaction or class of transaction or class of associated person or functions performed by such persons or such other relevant factors

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

ITA 303/BANG/2022[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18
For Appellant: \nShri Chaitanya, Sr. Advocate a/wFor Respondent: \nMs. Neera Malhotra, CIT-DR
Section 143(2)Section 143(3)Section 92C

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production