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574 results for “depreciation”+ Section 92clear

Sorted by relevance

Mumbai1,602Delhi1,338Bangalore574Chennai360Kolkata255Ahmedabad208Jaipur107Hyderabad98Chandigarh96Pune67Indore42Raipur39Visakhapatnam34Lucknow28Karnataka25Guwahati21Ranchi18Rajkot18SC17Telangana17Surat16Cochin16Amritsar11Nagpur10Kerala8Cuttack5Allahabad5Varanasi4Agra3Jodhpur3Panaji2Jabalpur2Patna2Calcutta1MADAN B. LOKUR S.A. BOBDE1A.K. SIKRI N.V. RAMANA1Dehradun1Gauhati1Rajasthan1Orissa1

Key Topics

Addition to Income83Section 143(3)76Transfer Pricing47Section 14A46Disallowance45Section 92C42Depreciation37Section 1134Deduction30Comparables/TP

M/S CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result, the appeal is partly allowed

ITA 129/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2014-15 M/S. Continental Automotive Vs. Dcit, Components India Pvt. Ltd., Circle – 2(1)(1), Plot No.53B, Bommasandra Industrial Bengaluru. Area, Hosur Road, Attibele Hobli, Anekal Taluk, Bengaluru–560 099. Pan : Aakcs 9578 C Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Shri. Mudavathu Harish Chandra Naik, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 21.03.2022 Date Of Pronouncement : 29.03.2022 O R D E R

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Shri. Mudavathu Harish Chandra Naik, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

92(l) of the Act provides that any income arising from an "international transaction" shall be computed having regard to the arms length price. The Explanation to the said section provides that allowance for any expense or interest arising from an international transaction hall also be determined having regard to the arm' s length price. • The term "international transaction

Showing 1–20 of 574 · Page 1 of 29

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27
Section 14826
Section 133A25

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

section 43(1) of the Act held that depreciation would be admissible only with reference to the WDV of the assets (as appearing in the books of IRIL on basis of Form 3CEA report) forming part of the business purchased by the appellant and not with reference to the values on the basis of valuer’s report. Accordingly, the assessing

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2135/BANG/2018[2010-11]Status: DisposedITAT Bangalore14 Nov 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

Section 32(1)(ii) with effect from the year 1998-99 which has been further amended w.e.f. Assessment Year 2003-04. In this view of the mater, we are inclined to hold that the assessee is entitled to depreciation as charged to the P & L account in accordance with its business exigencies. We direct accordingly. On the claim of deduction/s.80G

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2139/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

Section 32(1)(ii) with effect from the year 1998-99 which has been further amended w.e.f. Assessment Year 2003-04. In this view of the mater, we are inclined to hold that the assessee is entitled to depreciation as charged to the P & L account in accordance with its business exigencies. We direct accordingly. On the claim of deduction/s.80G

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2137/BANG/2018[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

Section 32(1)(ii) with effect from the year 1998-99 which has been further amended w.e.f. Assessment Year 2003-04. In this view of the mater, we are inclined to hold that the assessee is entitled to depreciation as charged to the P & L account in accordance with its business exigencies. We direct accordingly. On the claim of deduction/s.80G

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2136/BANG/2018[2011-12]Status: DisposedITAT Bangalore14 Nov 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

Section 32(1)(ii) with effect from the year 1998-99 which has been further amended w.e.f. Assessment Year 2003-04. In this view of the mater, we are inclined to hold that the assessee is entitled to depreciation as charged to the P & L account in accordance with its business exigencies. We direct accordingly. On the claim of deduction/s.80G

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2138/BANG/2018[2013-14]Status: DisposedITAT Bangalore14 Nov 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

Section 32(1)(ii) with effect from the year 1998-99 which has been further amended w.e.f. Assessment Year 2003-04. In this view of the mater, we are inclined to hold that the assessee is entitled to depreciation as charged to the P & L account in accordance with its business exigencies. We direct accordingly. On the claim of deduction/s.80G

M/S. SYNGENE INTERNATIONAL LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 6, BANGALORE

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

ITA 147/BANG/2020[2010-11]Status: DisposedITAT Bangalore13 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2010-11

For Appellant: Sri Padamchand Khincha, A.RFor Respondent: Sri Sumer Singh Meena, DR
Section 10ASection 10BSection 14ASection 250Section 32(1)(iia)Section 80

depreciation under section 32(1)(iia) of the Act. 5 Addition under section 14A of the Act 5.1 The Learned CIT(A) has erred in law and on facts in making an addition under section 14A of the Act by applying Rule 8D of the Income-tax Rules, 1962 ("the Rules") 5.2 The Learned CIT(A) has erred

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

Section 35 (1) (iv) of the Act without any discussion.” Following questions were posed before the Hon’ble High Court in one of the several appeals filed before it and the Hon’ble Karnataka High Court decided this issue in favour of the assessee taking note of technological obsolescence and also following the decision rendered by Hon’ble Supreme Court

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)

depreciation or the question of allowing it u/s 35(1)(iv) as Scientific research expenses shall become academic and we are not adjudicating them. 7. The fifth issue relates to the transfer pricing adjustment made by TPO/AO. This adjustment consists following three items:- (a) Adjustment for interest on advances given to Overseas subsidiaries. (b) Adjustment made for Corporate guarantee commission

M/S TE CONNECTIVITY INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2 LTPU , BANGALORE

In the result, the appeal by the assessee is treated as partly allowed for 37

ITA 3373/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.3373/Bang/2018 Assessment Year : 2014-15 M/S. Te Connectivity India Private Limited, Vs. Acit, Te Park, 22B, Doddenakundi Corporation, 2Nd Circle - 2, Large Taxpayer Unit, Phase, Industrial Area, Whitefield Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 7374 C Assessee Respondent Assessee By : Shri. Sriram Seshadri, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 22.02.2022 Date Of Pronouncement : 25.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Sriram Seshadri, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C

depreciation under section 32 of the Act is a mandatory allowance goodwill arising on merger satisfied the conditions specified under section 32(1)(ii) of the Act, as certified in the tax audit report IT(TP)A No.3373/Bang/2018 Page 5 of 33 ISSUE GROUNDS OF APPEAL (“GoA”) issued by Chartered Accountant. 14. Disallowance 14.1. The lower authorities erred in disallowing

KENNAMETAL INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

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

ITA 506/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 92C

section 92 of the Act can be applied only in respect of international transactions i.e., transactions with AE. 53. In view of the above transfer pricing provisions and various judicial precedents, we hold that the transfer pricing adjustment should be restricted only to the AE related transactions of the assessee.” 74. The facts and circumstances of the case in this

M/S. CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed

ITA 280/BANG/2021[2016-17]Status: DisposedITAT Bangalore06 Feb 2023AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 234BSection 92C

depreciation adjustment. 39. Respectfully following the above decision we hold and direct accordingly. 40. Through Ground No.15, the assessee is seeking exclusion of certain comparable companies chosen by the TPO. 41. The ld AR presented written submissions with regard to the exclusions the extract of which is as given below – IT(TP)A No.280/Bang/2021 Page 24 of 115 Aditya Auto

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

ITA 2806/BANG/2017[2013-14]Status: DisposedITAT Bangalore02 Mar 2023AY 2013-14

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Sunil Kumar Singh, CIT (D.R)
Section 143(3)Section 92C(2)

depreciation that means it has been put to use and capital expenses should be treated as operating in nature. In this regard, the assessee could not give any satisfactory answer. In the opinion of the AO, he also noted from the computation of income that no such adjustment was made by the assessee. Accordingly, he noted that two different opinions

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

In the result, the appeal of the assessee is allowed

ITA 2512/BANG/2019[2016-17]Status: DisposedITAT Bangalore09 Nov 2020AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojarim/S. Safina Hotels Pvt. Ltd., 84/85, Safina Plaza, Infantry Road, Bangalore-560 001 ….Appellant Pan Aaccs 5146G Vs. Dy. Commissioner Of Income Tax, Circle 6(1)(1), Bangalore. ……Respondent. Assessee By: Shri Tata Krishna, Advocate. Revenue By: Shri Kannan Narayanan, Jcit(D.R)

For Appellant: Shri Tata Krishna, AdvocateFor Respondent: Shri Kannan Narayanan, JCIT(D.R)
Section 143(2)Section 143(3)Section 32Section 37

depreciation on the motor car under Section 32 of the IT Act, solely based on their perverse observation that the appellant was not engaged in business. 4.3 Without prejudice to the above, the Lower Authorities have failed to appreciate that the appellant had carried on the business of operation of hotel in the past by taking the hotel property

M/S TE CONNECTIVITY INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU,CIRCLE-1, , BENGALURU

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

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 40Section 92

section 92 of the Act apply. The assessee also trades in AMP Netconnect cables and switches which are used in providing IT networking solutions to commercial premises. The assessee buys interconnectors from Tyco group and sells them to auto ancillaries in India and to various other industrial schemes. The assessee is also engaged in sourcing of raw materials and components

M/S. VEE TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-7, BENGALURU

In the result, appeal of the assessee is partly allowed

ITA 7/BANG/2022[2014-15]Status: DisposedITAT Bangalore07 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. The Principal Commissioner Of Income Tax, No.71, Sona Towers, Millers Road, Bengaluru – 7, Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent It(Tp)A No.2042/Bang/2019 Assessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. Ito, No.71, Sona Towers, Millers Road, Ward – 7[1][2], Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent Appellant By : Shri. Suresh Muthukrishna, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 02.03.2022 Date Of Pronouncement : 07.03.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. Suresh Muthukrishna, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10BSection 143(3)Section 263Section 92C

section 92D(3) of the Act, the assessee did not give any reply. The TPO therefore proceeded to determine the ALP on the basis of facts available on record. The TPO noticed that the assessee is a leading global business process management company. The assessee provides Information Technology enabled Services (ITeS) to its AE. The assessee also had transactions

M/S. VEE TECHNOLOGIES PRIVATE LIMITED,BENGALURU vs. THE INCOME TAX OFFICER, WARD- 7(1)(2), BENGALURU

In the result, appeal of the assessee is partly allowed

ITA 2042/BANG/2019[2014-15]Status: DisposedITAT Bangalore07 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. The Principal Commissioner Of Income Tax, No.71, Sona Towers, Millers Road, Bengaluru – 7, Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent It(Tp)A No.2042/Bang/2019 Assessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. Ito, No.71, Sona Towers, Millers Road, Ward – 7[1][2], Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent Appellant By : Shri. Suresh Muthukrishna, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 02.03.2022 Date Of Pronouncement : 07.03.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. Suresh Muthukrishna, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10BSection 143(3)Section 263Section 92C

section 92D(3) of the Act, the assessee did not give any reply. The TPO therefore proceeded to determine the ALP on the basis of facts available on record. The TPO noticed that the assessee is a leading global business process management company. The assessee provides Information Technology enabled Services (ITeS) to its AE. The assessee also had transactions

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

depreciation of goodwill back to the file of Assessing Officer with the directions to adjudicate the issue afresh after taking into consideration the additional evidences now filed by the Assessee. It is clarified that we have not expressed any opinion on the merits of the matter and all the rights and contentions of both the sides have been left open

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

ITA 187/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Apr 2019AY 2010-11

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

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Smt. Susan D. George, CIT-DR
Section 143(1)Section 143(3)Section 144C(5)Section 36(1)(iii)Section 92CSection 92C(2)

92 B runs counter to legal position explained in CIT v. EKL Appliances Ltd. (supra) which required a IT(TP)A No.187/Bang/2015 Page 32 of 50 TPO "to examine the ‘international transaction’ as he actually finds the same.”62. In the present case, the mere fact that B&L, USA through B&L, South Asia, Inc holds