NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

144C(13) of the Act dated 30/10/2025, the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paper book comprising of 17 pages containing therein the copy of notice u/s. 148A(b) of the Act, copy of the order u/s. 148A(d) of the Act, copy of notice u/s. 148 of the Act along

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

144C(13) of the Income- tax Act,1961 ['the Act' for short] in pursuance of directions issued by Ld Dispute Resolution Panel (DRP). The assessee has filed the appeals for assessment years 2009-10 to 2014-15. The revenue has filed the appeals for assessment years 2009-10 to 2011-12. Since most of the issues urged in these appeals

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

144C(13) of the Income- tax Act,1961 ['the Act' for short] in pursuance of directions issued by Ld Dispute Resolution Panel (DRP). The assessee has filed the appeals for assessment years 2009-10 to 2014-15. The revenue has filed the appeals for assessment years 2009-10 to 2011-12. Since most of the issues urged in these appeals

M/S SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

1) of the Act to be eligible for depreciation other than the one prescribed for "Plant and machinery". 8. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in deleting the disallowance made under section 40(a)(ia) on depreciation on computer software without appreciating that the same is contrary to the provisions

D.C.I.T., BANGALORE vs. M/S SAP LABS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

1) of the Act to be eligible for depreciation other than the one prescribed for "Plant and machinery". 8. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in deleting the disallowance made under section 40(a)(ia) on depreciation on computer software without appreciating that the same is contrary to the provisions

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

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

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 144C(5). On the facts and in the circumstances of the case and in law, the Ld. c) Panel and Ld. AO/ Ld. TPO erred in not demonstrating that the motive of the Appellant was to shift profits outside India by manipulating the prices charged in the international transaction, which is a pre- requisite condition to make any adjustment

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

section 144C(1) of the Act. In the draft assessment order so passed the Ld.AO:- • disallowed depreciation on computer software

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

144C of the Act dated 22.6.2015 passed by Deputy Commissioner of Income-tax (LTU) Circle-1, Bangalore. The said order was received by the assessee on 29.6.2015 and the appeal was filed by the assessee on 3.11.2021. Thus, there was delay of 1694 days in filing the appeal before this Tribunal. The assessee attributed the delay on the reason

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

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

Section 144C(1) of the Act on 29/09/2003 proposing the following additions/disallowance adjustments: a) Transfer Pricing (TP) adjustment amounting to Rs.16,00,55,328/- b) Disallowance of Depreciation

M/S THE HIMALAYA DRUG COMPANY,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal for Assessment Year 2011-12 is partly allowed

Bench: Shri Jason P Boaz & Shri Laliet Kumarit(Tp)A No.187/Bang/2015 Assessment Year : 2010-11

144C of the Act vide order dated 29.12.2014 wherein the assessee’s income was determined at Rs.115,63,22,141/- in view of the aforesaid TP adjustments and disallowance of interest under section 36(1)(iii) of the Act. IT(TP)A No.187/Bang/2015 Page 3 of 50 3. The assessee initially filed XVI grounds of appeal. However it subsequently filed

D.C.I.T., BANGALORE vs. M/S SWISS RESHARED SERVICES INDIA PVT. LTD.,, BANGALORE

In the result, the appeal filed by the assessee stands allowed on the legal issue

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 290/Bang/2015 Assessment Year : 2010-11 M/S. Swiss Re Global Business Solution India Pvt. Ltd. (Previously Known As Swiss Re The Deputy Shared Services India Pvt. Ltd.), Commissioner Of 2Nd To 5Th Floor, Fairwinds Income Tax, Building, Embassy Golf Links Circle – 6(1)(2), Business Park, Challaghatta Vs. Bangalore. Village, Varthur Hobli, Bangalore, Karnataka – 560 071. Pan: Aaecs8786L Appellant Respondent & It(Tp)A No. 438/Bang/2015 Assessment Year : 2010-11 (By Revenue) : Shri Nageswar Rao, Assessee By Advocate : Shri Sumer Singh Revenue By Meena, Cit Dr (Osd) Date Of Hearing : 23-12-2021 Date Of Pronouncement : 30 -12-2021 Order Per Bench Present Appeal Is Filed By Assessee Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Grounds Of Appeal.

section 144C(13) of the Income-tax Act, 1961 ("the Act") on the following grounds: That on the facts and circumstances of the case and in law: 1. The learned AO, based on directions of the Hon'ble DRP, erred in assessing the total income at Rs. 4,89,94,919/- as against returned income

M/S. TE CONNECTIVITY SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.300/Bang/2021 Assessment Year : 2016-17

144C(13) r.w.s. 144B of the Income-tax Act, 1961 [the Act] dated 30.4.2021. 2. The assessee was incorporated on 18.05 2015, as a wholly owned subsidiary of Tyco Electronics Singapore Pte Ltd, Singapore, and is engaged in providing ITeS in the nature of shared services in the areas of Information Technology, Finance back-office, Human Resource, customer support