EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together. 2. First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

250 of\nthe Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to\n2021-22, which were heard together.\n2.\nFirst, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017-\n18 as the lead case. The assessee, in the memo of appeal, has raised\nfour grounds bearing numbers

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

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

250 of the Income Tax Act, 1961 (in short “the Act”) for the Assessment Year (AY) 2017-18. The assessee has not filed any cross objections (CO) against this appeal filed by the Revenue. 2. The Revenue has raised the following grounds of appeal: - Dcit(E), Circle-1, Bengaluru Page 2 of 24 Dcit(E), Circle-1, Bengaluru Page

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

250 of the Act by the learned CIT(A),\nNFAC to the extent prejudicial to the appellant be quashed\nor in the alternative the above grounds and the relief\nprayed thereunder be allowed.\nThe Appellant submits that each of the above grounds/\nsub-grounds are independent and without prejudice to one\nanother.\nThe Appellant craves leave to add, alter, vary

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

250 of the Act by the learned CIT(A),\nNFAC to the extent prejudicial to the appellant be quashed\nor in the alternative the above grounds and the relief\nprayed thereunder be allowed.\nThe Appellant submits that each of the above grounds/\nsub-grounds are independent and without prejudice to one\nanother.\nThe Appellant craves leave to add, alter, vary

M/S TRILOGY E- BUSINESS SOFTWARE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee as well as the revenue are partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raoi.T. (T.P.) A. No.33/Bang/2013 (Assessment Year : 2008-09) M/S. Trilogy E-Business Software India Pvt. Ltd., No.1/2, Lalitha Nilaya, 4Th Cross, Rmv 2Nd Stage, Bhopsandra, Bangalore-560 094. …. Appellant. Vs. Dy. Commissioner Of Income Tax, Circle 12(4), Bangalore-560 001. ….. Respondent. I.T. (T.P.) A. No.115/Bang/2013 (Assessment Year : 2008-09) (By Revenue) Assessee By : Shri Padam Chand Khincha, C.A. Respondent By : Dr.P.K. Srihari, Addl. Cit (D.R.) Date Of Hearing : 18.5.2016. Date Of Pronouncement : 08.06.2016. O R D E R Per Shri Vijay Pal Rao, J.M. : These Cross Appeals Are Directed Against The Order Dated 6.11.2012 Of Commissioner Of Income Tax (Appeals)-Iv, Bangalore For The Assessment Year 2008-09. 2 It(Tp)A Nos.33 & 115/Bang/2013 2. The Assessee-Company Was Incorporated In June 2000 & Is Wholly Owned Subsidiary Of Versata International Inc., (Previously Known As Trilogy Inc.). During The Financial Year Relevant To The Assessment Year Under Consideration, The Assessee Has Provided Software Development Services As Well As Call Centre Services To Its Associated Enterprises (In Short ‘Aes’). The Assessee Is Compensated On Cost +10% Basis By Its Aes For The Services Provided By The Assessee. The Financial Results Of The Assessee For The Assessment Year Under Consideration Are Recorded By The Transfer Pricing Officer (In Short ‘Tpo’) In Paragraph 2.1 As Under :

250(6) on 06.11.2012. 2. In the order passed under section 143(3), transfer pricing additions were made for transactions with associated enterprises along with certain other additions to the total income of the Appellant. 3. The additional grounds of appeal (enclosed herewith) relate to rejection of Quintegra Solutions Ltd, Soft Sol India Ltd, E-Zest Solutions Ltd and Persistent

M/S HINDUSTAN AERONAUTICS LTD ,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 George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LTD ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX CIRCLE-3(1)(2), BANGALORE

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

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LTD ,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 George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LIMITED ,BANGALORE vs. ASSISTANT 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 George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE , BANGALORE

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

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LTD ,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 George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

M/S HINDUSTAN AERONAUTICS LIMITED ,BANGALORE vs. ASSISTANT 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 George George K, Jm & Shri B.R.Baskaran, Am

depreciation on the same. 6. That the learned CIT(A) erred in not granting TDS credit available to the company. 7. That the learned CIT(A) erred in law and facts in upholding the order of the learned Assessing Officer in levying interest under section 234B & 234C of the Act. 8. That the Appellant craves leave

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

250 of\nthe Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to\n2021-22, which were heard together.\n2.\nFirst, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017-\n18 as the lead case. The assessee, in the memo of appeal, has raised\nfour grounds bearing numbers

AMD INDIA PVT. LTD.,,BANGALORE vs. ITO,

In the result, the appeal by the Revenue is dismissed, while the appeal by the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Abraham P. George

250 of the Act, are bad in law and on facts and is in violation of the principles of natural justice. b) The AO has erred in making a reference to the Additional Commissioner of Income-tax, (Transfer Pricing) - I, Bangalore [‘TPO’], inter alia, since AMD India Private Limited [‘AMD India’ or ‘the Appellant’] has satisfied all the conditions

ITO vs. M/S AAMD INDIA PVT. LTD.,,

In the result, the appeal by the Revenue is dismissed, while the appeal by the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Abraham P. George

250 of the Act, are bad in law and on facts and is in violation of the principles of natural justice. b) The AO has erred in making a reference to the Additional Commissioner of Income-tax, (Transfer Pricing) - I, Bangalore [‘TPO’], inter alia, since AMD India Private Limited [‘AMD India’ or ‘the Appellant’] has satisfied all the conditions

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

250 of the Act by the learned CIT(A), NFAC to the extent prejudicial to the appellant be quashed or in the alternative the addition of Rs.1,09,55,534/- made under section 10AA and consequential levy of tax including interest thereon be deleted. The Appellant submits that each of the above grounds / sub-grounds are independent and without prejudice