ASTRAZENECA PHARMA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.

disallowance of ESOP expenses made under Section 37(1) of the Act. 8. The ld. D.R. submitted that ESOP issue is covered by APA dated 16.6.2023. No further deduction to be allowed. 9. We have heard the rival submissions and perused the materials available on record. In our opinion, this is an allowable expenditure in view of the judgement

EBIX TRAVELS PVT. LTD.,NEW DELHI vs. DCIT,CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result appeal of the assessee is partly allowed

disallowance\nof depreciation of ₹ 1,845,615 was added to the total income\npursuant to the direction passed by The Dispute Resolution\nPanel 1, New Delhi (the learned DRP) dated 27/9/2024 in\nthe draft assessment order passed on 26/12/2023 wherein the\norder under section 92CA (3) was passed by the learned TPO\nproposing the adjustment.\n2. Assessee is aggrieved with

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

disallowance;\n(d)the amount of under-reported income represented by any addition made in\nconformity with the arm's length price determined by the Transfer Pricing Officer,\nwhere the assessee had maintained information and documents as prescribed\nunder section 92D

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

92D and 92E, "specified domestic transaction" in case of an assessee means any of the following transactions, not being an international transaction, namely:— (i) any expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of sub- section (2) of section 40A;* (ii) any transaction referred

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 177/Bang/2022 (Assessment Year: 2017-18)

section 92D of the Income Tax Act, 1961 ('the Act') read with Rule 10D of the Income- tax Rules, 1962 ('the Rules') and thereby erred in rejecting the TP documentation maintained by the Appellant. 3:3 The AO/TPO/DRP have erred in rejecting the detailed functional and economic analysis and methodical search process undertaken by the Appellant to identify Page

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

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

Section 92D of the Act, in good faith and with due diligence; 6.2. Rejecting the filters selected by the Appellant as captured in the TP documentation and adopting certain addition filters which are not in accordance with the jurisprudence laid down by various appellate forums; 6.3. Application of related party transaction (‘RPT’) filter by applying an inappropriate interpretation of computing

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

disallowance; (d)the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE vs. L JAVERCHAND JEWELLERS PRIVATE LIMITED, MUMBAI

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20 L. Javerchand Jewellers Pvt. Ltd. No.1, 2Nd Floor & 3Rd Floor, Choksi Chamber Dcit 1Stagyari Lane Vs. Central Circle-1 Zaveri Bazar Mangaluru Mumbai 400 002

disallowance; (d)the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

disallowance; (d)the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D

LENOVO (INDIA) PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD- 4(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for above terms

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

disallowing the unrealized foreign exchange loss amounting to INR 17,55,00,000 claimed as a deduction under section 37 of the Act while computing the taxable income. 48. The Honourable DRP and learned AO have erred in law and on facts by treating the unrealized foreign exchange loss as marked-to-market loss, arising to the Appellant on account

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. THE ASSESSING OFFICER, NFAC, DELHI, BANGALORE

In the result, appeal of the assessee is partly allowed

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

section 271(1)(c) of the act mechanically and without recording any adequate satisfaction for such initiation Each of the above grounds is independent and without prejudice to the other grounds of appeal preferred by the Appellant. The Appellant prays for leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before