BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

328 results for “depreciation”+ Section 144C(8)clear

Sorted by relevance

Mumbai613Delhi573Bangalore328Kolkata80Chennai73Hyderabad54Ahmedabad48Pune31Chandigarh13Indore9Jaipur9Cochin8Dehradun7Karnataka5Surat5Visakhapatnam3Panaji2Nagpur1Raipur1Rajkot1SC1Kerala1Telangana1Guwahati1

Key Topics

Section 143(3)102Transfer Pricing71Addition to Income64Section 92C52Comparables/TP47Disallowance39Depreciation33Section 4030Deduction26

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

ITA 1537/BANG/2012[2008-09]Status: DisposedITAT Bangalore08 May 2019AY 2008-09

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

For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 139Section 143Section 143(3)Section 144Section 153(1)Section 18

144C gives a complete go bye to section 153; and (ii) The Act does not contemplate any limitation for passing of draft assessment order, which can be passed within a reasonable time. 14. Though arguments were advanced that the aforesaid decision does not lay down the correct law, we are of the view that a co-ordinate Bench decision

Showing 1–20 of 328 · Page 1 of 17

...
Section 10A23
Section 14A20
Section 144C(13)17

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

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

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

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

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

BROCADE COMMUNICATIONS SYSTEMS PRIVATE LIMITED,BENGLURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, BENGALURU

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

ITA 656/BANG/2021[2013-14]Status: DisposedITAT Bangalore30 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Brocade Communications Systems Pvt. Ltd., Floor 3, B & C Wing & The Principal Floor 8, D Wing, S1 Commissioner Of Wipro Electronic City Income Tax – 1, Sez, Doddathogur Bengaluru. Vs. Village, Bengaluru – 560 100. Pan: Aaccb4490N Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Smt. Priyadarshini Revenue By Baseganni, Addl. Cit (Dr) Date Of Hearing : 28-07-2022 Date Of Pronouncement : 30-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Order Dated 18/03/2020 Passed By The Ld.Pr.Cit For A.Y. 2013-14 On Following Grounds Of Appeal: “1. The Order Of The Principal Commissioner Of Income Tax ('Pr.Cit') Passed Under Section 263 Of The Income-Tax Act, 1961 ('The Act'), Is Bad In Law & Liable To Be Quashed. 2. The Learned Pr.Cit Erred In Law & Facts In Concluding That The Order Of The Assessing Officer ('Ao') Is "Erroneous

For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143(3)Section 144C(5)Section 263Section 28Section 92C

144C(8) of the Act could not have exercised powers of enhancement on the aforesaid issue. Therefore, the Commissioner was free under section 263 of the Act to revise the order of the AO on the ground that the AO failed to make necessary enquiries before concluding the assessment.” Accordingly, Ground nos. 1-3 raised by assessee stands dismissed

M/S. PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal by the assessee is allowed

ITA 154/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Jun 2023AY 2017-18

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: S/Shri Dhanesh Bafna & Ali Asgar Rampurawala, CAFor Respondent: Shri Sunil Kumar Singh, CIT-2(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 92D

8 of 28 25,00,157/- on account of waiver of Royalty receivable on intellectual property licensed to Practo Pte Ltd (Singapore). 20. On the facts and in the circumstances of the case and in law, the learned AO has erred in not granting the set-off of the brought forward business losses and unabsorbed depreciation of prior years against

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

ITA 437/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

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.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

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 of Sec. 40(a)(ia) and Sec. 195J since the claim of depreciation is in the nature of business

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

ITA 561/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

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.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

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 of Sec. 40(a)(ia) and Sec. 195J since the claim of depreciation is in the nature of business

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R
Section 143(3)

144C(13) of the Income-tax Act,1961 ['the Act' for short] for assessment year 2015-16 in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. The assessee is engaged in different types of business activities, viz., software development services and IT services; manufacture of Vanaspati/Hydro generated oils; toilet soaps; lighting products; pharmaceuticals & Neutraceutical products; leather

INFINEON TECHNOLOGIES INDIA PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2008-09 is partly allowed

ITA 1670/BANG/2012[2008-09]Status: DisposedITAT Bangalore06 Nov 2015AY 2008-09

Bench: Smt. Asha Vijayaraghavan & Shri Jason P. Boazi.T. (T.P) A. No.1670/Bang/2012 S.P. No.120/Bang/2015 (Assessment Year : 2008-09) M/S. Infineon Technologies India Pvt. Ltd., Kalyani Platina, 3Rd Floor, Block 1, No.6 & 24, Epip Zone Phase 1, Whitefield, Bangalore-560 066 …. Appellant. Pan Aabcs 6967N Vs. Asst. Commissioner Of Income Tax, Circle 11(4), Bangalore. ….. Respondent. Appellant By : Shri K.R. Vasudevan, Advocate. Respondent By : Shri D. Sudhakara Reddy, Cit-Iii (D.R.) Date Of Hearing : 5.10.2015. Date Of Pronouncement : 6.11.2015. O R D E R Per Shri Jason P. Boaz, A.M. : This Appeal By The Assessee Is Directed Against The Order Of Assessment For Assessment Year 2008-09 By The Dcit, Circle 11(4), Bangalore Passed Under Section 143(3) Rws 144C Of The Income Tax Act, 1961 (In Short 'The Act') Vide Order Dt.29.10.2012, In Pursuance Of The Directions Issued By The Dispute Resolution Panel (‘Drp’) Under Section 144C(5) Rws 144C(8) Of The Act Vide Order Dt.17.9.2012. 2. The Facts Of The Case, Briefly, Are As Under :-

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri D. Sudhakara Reddy, CIT-III (D.R.)
Section 143(3)Section 144C(5)Section 92C

144C of the Act dt.29.10.2012 assessing the taxable income of the assessee at Rs.58,69,63,275 by making the following additions/disallowances :- (i) T.P. Adjustment : Rs.26,13,69,735. (ii) Project Specific Cost : Rs.11,25,95,270. 3.1 Aggrieved by this final order of assessment for Assessment Year 2008-09 dt.29.10.2012, the assessee is in appeal before this Tribunal. Before

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

ITA 370/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jun 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sandeep Huilgol, AdvocateFor Respondent: Dr. Manjunath Karkihallli, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(2)Section 143(3)Section 80G

144C(13) r.w.s. 144B of the Income-tax Act,1961 ['the Act' for short] for assessment year 2016-17 in pursuance of directions given by Ld Dispute Resolution Panel (DRP) dated 29.03.2021. IT(TP)A No.370/Bang/2021 Page 2 of 110 2. The brief facts of the case are that the assessee filed his return of income on 30.11.2016 declaring

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

depreciation under section 32 of the Act ought to be allowed.; and 14.2.2. Treating balance AMP expenditure of INR 31,02,747 as capital in nature even though it was incurred for the purpose of day-to-day business operations of the Appellant and is within the 20% threshold adopted by Learned AO making the said adjustment. The Learned

M/S INFINEON TECHNOLOGIES INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

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

ITA 159/BANG/2019[2006-07]Status: DisposedITAT Bangalore04 Mar 2020AY 2006-07

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadalem/S. Infineon Technologies India Pvt. Ltd., 9Th Floor, Prestige Thirulakshmi, No.11, Mg Road, Bangalore-560001 ….Appellant Pan Aabcs 6967N Vs. Dy. Commissioner Of Income Tax, Circle 3(1)(1), Bangalore. ……Respondent.

For Appellant: Shri K.R. Vasudevan,& Smt Vidya kurup AdvocateFor Respondent: Shri Pradeep Kumar, CIT (D.R)
Section 143(3)Section 144CSection 144C(5)Section 92C

144C of the Act with total income of Rs.9, 86,91,148/- after considering the relief granted by the DRP in Transfer Pricing Adjustment. Aggrieved by the order, the assessee has filed an appeal before the Tribunal. 6. At the time of hearing, the learned Authorized Representative has argued only Ground Nos.14, 16 & 17. Whereas Ground No.14 relates to exclusion

KAWASAKI MICROELECTRONICS INC,BANGALORE vs. DDIT INTERNATIONAL TAXATION, BANGALORE

In the result, the appeal of the assessee is allowed

ITA 1512/BANG/2010[2007-08]Status: DisposedITAT Bangalore26 Jun 2015AY 2007-08

Bench: Shri Vijaypal Rao & Shri Jason P. Boaz

For Appellant: Shri Chavali Narayan, C.AFor Respondent: Shri Farhat Hussain Qureshi, CIT (D.R)
Section 10ASection 143(3)Section 144C(5)Section 4Section 40

144C(5) of the Act for Assessment Year 2007-08. 2 IT(I.T)A No.1512/Bang/2010 2. The assessee has raised the following grounds :- “1. The order of the learned AO and direction of the Hon’ble DRP are based on incorrect interpretation of law and therefore are bad in law. 2. Based on directions of DRP, the learned AO erred

M/S. TOYOTA KIRLOSKAR MOTOR PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, , BENGALURU

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

ITA 1333/BANG/2024[2011-12]Status: DisposedITAT Bangalore20 Dec 2024AY 2011-12

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2011-12 M/S. Toyota Kirloskar Motor Pvt. Ltd. Plot No.1, Bidadi Industrial Area So Bidadi Acit Vs. Ramanagar Ltu, Circle-1 Bengaluru 562 109 Banalore Pan No : Aaact5415B Appellant Respondent Appellant By : Sri Padam Chand Kincha, A.R. Respondent By : Smt. Kumutha D., D.R. Date Of Hearing : 24.09.2024 Date Of Pronouncement : 20.12.2024

For Appellant: Sri Padam Chand Kincha, A.RFor Respondent: Smt. Kumutha D., D.R
Section 143(1)Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 250

8 of 17 6.3 Further, the ld. DR submitted that the provisions of Section 144C(13) mandates that upon receipt of the directions issued u/s 144C(5) by the DRP, the AO has to pass the Order in conformity with the directions without providing any further opportunity of being heard to the Assessee within one month from

SRI. PAVAN KANDKUR,HUBBALLI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, HUBBALLI

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

ITA 522/BANG/2022[2017-18]Status: DisposedITAT Bangalore17 Nov 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.Shri Pavan Kandkur Vs Principle Commissioner Of Cts No. 3046, Hirepeth Nagar Income Tax Near Akkikonda Aayakar Bhavan Hubballi 580020 Navanagar Pan – Anipk4256B Hubballi 580025 (Appellant) (Respondent) Assessee By: Shri Balram R. Rao, Adv. Revenue By: Ms. Neera Malmotra, Cit-Dr Date Of Hearing: 15/11/2022 Date Of Pronouncement: 17/11/2022 O R D E R Per: Padmavathy, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Learned Cit, Hubali Passed Under Section 263 Of The Income Tax Act, 1961 (The Act) Dated 23.03.2022 For Ay 2017-18. 2. The Assessee Raised The Following Grounds Of Appeal: - On The Facts & In The Circumstances Of The Case, The Conditions 1. Precedent Being Absent The Proceedings-Initiated U/S.263 Of The Act Was Opposed To Law & The Order Passed U/S.263 Is Liable To Be Cancelled. On The Facts There Being No Error Much Less An Error Prejudicial To The 2. Interest Of Revenue, The Learned Commissioner Of Income-Tax Ought To Have Refrained From Invoking The Provisions Of Sec.263 Of The Act. The Learned Commissioner Ought To Have Considered The Submissions 3. Made By The Appellant & Ought Not To Have Invoked The Proceedings U/S.263 Of The Act.

For Appellant: Shri Balram R. Rao, AdvFor Respondent: Ms. Neera Malmotra, CIT-DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 263Section 40A(3)Section 5(3)Section 8

144C of the Income-tax Act and the Assessing Officer has not passed the order under sub-section (13) of that section on or before the specified date, the amount of tax payable by the appellant as per the assessment order to be passed by the Assessing Officer under subsection (13) thereof; (F) in a case where an application

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

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

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

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

144C(1) of the Act. In the draft assessment order so passed the Ld.AO:- • disallowed depreciation on computer software at Rs.7,46,162/- for non-deduction of TDS; • disallowed payments on which TDS was not deducted under section 40(a)(ia) of the Act at Rs.7,46,162/-; • disallowed professional charges for non-deduction of TDS under section

TEKTRONIX (INDIA) PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

ITA 673/BANG/2017[2007-08]Status: DisposedITAT Bangalore17 Mar 2020AY 2007-08

Bench: Shri. A. K. Garodia & Smt. Beena Pillaiit(Tp)A 673/Bang/2017 Assessment Year : 2007 – 08

For Appellant: Shri Sharath Rao, CAFor Respondent: Mr. Muzaffar Hussain, CIT – DR
Section 143Section 143(3)Section 144CSection 144C(13)Section 147Section 148

144C(13) of the Income- tax Act, 1961 ("Act") is not in accordance with the law and is contrary to the facts and circumstances of the present case. 2. Reopening of Assessment: 2.1 The Honourable Dispute Resolution Panel ("DRP") erred in upholding the reassessment proceedings initiated under section 147 of the Act without appreciating that no "fresh tangible material

M/S. HIMALAYA WELLNESS COMPANY (FORMERLY KNOWN AS THE HIMALAYA DRUG COMPANY),BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(1), BENGALURU

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

ITA 259/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Jun 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.259/Bang/2022 : Asst.Year 2017-2018 M/S.Himalaya Wellness Company The Deputy Commissioner Of (Formerly Known As The Himalaya Income-Tax, Circle 6(1)(1) V. Bengaluru. Drug Company), Makali, Tumkur Road Bengaluru – 562 162. Pan : Aadft3025B. (Appellant) (Respondent)

For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Sri.Sumer Singh Meena, CIT -DR
Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 2(11)Section 92C

8) of the 3 IT(TP)A No.259/Bang/2022 M/s.Himalaya Wellness Company. I.T.Act. The DRP dismissed the objection of the assessee. The A.O. considering the directions of the DRP, passed final assessment order u/s 143(3) r.w.s. 144C of the I.T.Act dated 17.02.2022 and determined total income of Rs.414,86,12,580. Aggrieved by the final assessment order, the assessee

M/S CISCO SYSTEMS CAPITAL (INDIA) PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result appeal filed by assessee for assessment years 2008-09 and 2009-10 stands allowed on legal issue raised and appeals filed by revenue for assessment years

ITA 900/BANG/2019[2008-09]Status: DisposedITAT Bangalore06 Mar 2020AY 2008-09

Bench: Shri. Pradip Kumar Kedia & Smt. Beena Pillai

For Appellant: Shri. Rajan Vora, CAFor Respondent: Ms. Neera Malhotra, CIT – DR
Section 143Section 143(3)Section 144CSection 254Section 263Section 292BSection 92Section 92C

8. ESPN Sports Mauritius S.N. C. ET Compagnie Vs. Union of India [2016] 388 ITR 383 (Del.). 5. On the contrary, Ld. CIT DR submitted that, there is nothing in the wording of section 144C (1) which would indicate that this requirement of passing draft assessment order in the remand proceedings of an issue by ITAT is to be satisfied

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

ITA 300/BANG/2021[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

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

For Appellant: Shri Sriram Sheshadri & Ms. Amulya K., CAsFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)

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

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

ITA 1608/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

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]

For Appellant: Sri Chavali NarayanFor Respondent: Sri Muthu Shankar
Section 143(3)Section 144C(1)Section 144C(13)Section 200ASection 234ASection 234BSection 234CSection 270ASection 274Section 28

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 claimed on Goodwill amounting to INR.3,08,21,235/- c) Addition on account of Free of Cost Assets amounting to INR.1,93,90,395/-, d) Addition