M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6N, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

M/S. SLK SOFTWARE PRIVATE LIMITED,BENGALURU vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6, BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

disallowances made under section 40(a)(i). However, the Ld. CIT(A) without considering the argument forwarded by the assessee proceeded to dismiss the appeal of the assessee without assigning any reasoning. The relevant findings of the ld. CIT-A is reproduced as under: “5.3.3 The facts of the case, assessment order and submissions of the appellant have been considered

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 under section 14A of the Äct by mechanically applying Rule 8D when there is no basis to reject the Appellant's claim that no expenditure was incurred for earning exempt income. IT(TP)A No.298/Bang/2024 Goldman Sachs Services Pvt. Ltd., Bangalore Page 7 of 14 2.3 The Honorable DRP and the Learned AO have erred

BRIGADE ENTERPRISES LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX,, BANGALORE

In the result, the assessee’s appeal is treated as partly allowed

Bench: Smt. P. Madhavi Devi & Shri Abraham P Georgem/S.Brigade Enterprises Ltd., 29Th & 30Th Floor, World Trade Centre, Brigade Gateway Campus, 26/1, Dr.Rajkumar Road, Rajajinagar, Bangalore-560055. … Appellant Pan: Aaacb7459F Vs. Addl. Commissioner Of Income-Tax, Range-11, Bangalore. … Respondent

section 80-IB(10) of the Act in respect of residential units having built up area of 1500 sq. ft. or less in ‘Brigade Gateway’ and ‘Brigade Metropolis’ housing projects. We, therefore, dismiss grounds No.2 to 6 raised by revenue in this appeal. ” Since the issue before us is similar to the issue in the earlier assessment year

NADATHUR ESTATES PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU

Appeal of the assessee is allowed for statistical purposes

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

250 of the Income-tax Act,1961 ['the Act' for short]. Since both the appeals have common and identical issue, they are heard together and disposed of by a consolidated order. 2. For the sake of convenience, we shall take up the appeal in ITA No.267/Bang/2018 and the facts narrated therein. The assessee has raised the following grounds of appeal

NADATHUR ESTATES PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU

Appeal of the assessee is allowed for statistical purposes

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

250 of the Income-tax Act,1961 ['the Act' for short]. Since both the appeals have common and identical issue, they are heard together and disposed of by a consolidated order. 2. For the sake of convenience, we shall take up the appeal in ITA No.267/Bang/2018 and the facts narrated therein. The assessee has raised the following grounds of appeal

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

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

250 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"): M/s. Syngene International Limited, Bangalore Page 2 of 29 1.Disallowance of relief claimed under section 10B of the Act 1.1 The Learned CIT(A) has erred in law arid in fact in disallowing the relief claimed under section 10B of the Act; 1.2 The Learned

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

250 of the Income-tax Act, 1961 ('Act'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. (a) That the learned CIT(A) erred in law and on the facts of the case in upholding the disallowance of INR 15,704,168 under section 14A of the Act read with Rule

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

250 of the Act to the extent prejudicial to the appellant is bad in law and liable to be quashed. 2. Assessment order passed is barred by limitation 2.1. The impugned assessment order passed under section 143(3) dated 17.2.2020 is barred by limitation in accordance with section 153(1) read with clause (iv) of Explanation 1 as well

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

250 of the Act to the extent prejudicial to the appellant is bad in law and liable to be quashed. 2. Assessment order passed is barred by limitation 2.1. The impugned assessment order passed under section 143(3) dated 17.2.2020 is barred by limitation in accordance with section 153(1) read with clause (iv) of Explanation 1 as well

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 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