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.

53 results for “disallowance”+ Section 92Fclear

Sorted by relevance

Delhi182Mumbai166Kolkata65Bangalore53Pune25Chennai20Ahmedabad10Jaipur8Hyderabad6Amritsar4Indore4Surat3Panaji2Karnataka2Calcutta2Raipur2Telangana1Cochin1Guwahati1Jabalpur1

Key Topics

Section 143(3)66Section 92C37Transfer Pricing35Section 10A34Addition to Income29Disallowance21Comparables/TP17Section 144C13Section 14812

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

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

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR
Section 10ASection 143(3)Section 144BSection 144C(13)

Showing 1–20 of 53 · Page 1 of 3

Deduction11
Section 143(2)9
Section 92A7

disallowing the said expense without giving cognizance to the facts of the Appellant and the various judicial precedents relied on by the Appellant. 7.4. The Hon'ble DRP has erred on facts and in law in holding that ESOP/ Employee Share Based Plan (`ESBP') expense does not satisfy conditions of section

M/S. IBM INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, appeal by the assessee for A

ITA 625/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Feb 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 625/Bang/2017 Assessment Year : 2012-13 M/S. Ibm India Pvt. Ltd., The Assistant No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent & It(Tp)A No. 1016/Bang/2019 Assessment Year : 2014-15 M/S. Ibm India Pvt. Ltd., The Joint No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Special Range-4, Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca : Shri K.V. Arvind, Standing Revenue By Counsel Date Of Hearing : 03-02-2022 Date Of Pronouncement : 14-02-2022

For Appellant: Shri Ajay Roti, CA
Section 10ASection 143(3)Section 144C(13)

disallowance under section 14A stands deleted. Accordingly this ground raised by assessee stands allowed.” Admittedly for year under consideration 11. Ground nos. 12 to 14 (A.Y. 2012-13) are consequential in nature. Page 15 of 21 IT(TP)A Nos. 625/Bang/2017 & 1016/Bang/2019 Accordingly the appeal filed by the assessee for Assessment Year 2012-13 stands allowed as indicated hereinabove

M/S. IBM INDIA PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 4, BANGALORE

In the result, appeal by the assessee for A

ITA 1016/BANG/2019[2014-15]Status: DisposedITAT Bangalore14 Feb 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 625/Bang/2017 Assessment Year : 2012-13 M/S. Ibm India Pvt. Ltd., The Assistant No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent & It(Tp)A No. 1016/Bang/2019 Assessment Year : 2014-15 M/S. Ibm India Pvt. Ltd., The Joint No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Special Range-4, Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca : Shri K.V. Arvind, Standing Revenue By Counsel Date Of Hearing : 03-02-2022 Date Of Pronouncement : 14-02-2022

For Appellant: Shri Ajay Roti, CA
Section 10ASection 143(3)Section 144C(13)

disallowance under section 14A stands deleted. Accordingly this ground raised by assessee stands allowed.” Admittedly for year under consideration 11. Ground nos. 12 to 14 (A.Y. 2012-13) are consequential in nature. Page 15 of 21 IT(TP)A Nos. 625/Bang/2017 & 1016/Bang/2019 Accordingly the appeal filed by the assessee for Assessment Year 2012-13 stands allowed as indicated hereinabove

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)

disallowance of interest under section 36(1)(iii) of the Act. IT(TP)A No.187/Bang/2015 Page 3 of 50 3. The assessee initially filed XVI grounds of appeal. However it subsequently filed the following concise grounds of appeal for consideration which are extracted hereunder: IT(TP)A No.187/Bang/2015 Page 4 of 50 IT(TP)A No.187/Bang/2015 Page

M/S PAGE INDUSTRIES LTD.,,BANGALORE vs. DCIT, BANGALORE

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

ITA 163/BANG/2015[2010-11]Status: DisposedITAT Bangalore24 Jun 2016AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Padamchand Khincha,CAFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 80JSection 92C

disallowing the deduction u/s 80JJA without appreciating that the conclusions reached are contrary to the provision of the Act and the binding precedents, especially in the Appellants own case. Addition made by AO 15 The learned AO has erred in: a) adding interest of Rs. 295,531 on delayed payment of dividend distribution tax ("DDT") to the tax payable

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)

disallowance made by the assessing officer could not be sustained. IT(TP)A No.2556/Bang/2019 M/s. Wipro Limited, Bangalore Page 26 of 85 6.22 Since we have held that these expenses are revenue in nature, the question of allowability of depreciation or the question of allowing it u/s 35(1)(iv) as Scientific research expenses shall become academic

TESCO HINDUSTAN SERVICE CENTRE PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee is allowed in the terms indicated above

ITA 1633/BANG/2012[2008-09]Status: DisposedITAT Bangalore18 Oct 2016AY 2008-09

Bench: Shri S.K.Yadav & Shri A. K. Garodiait (Tp) A No.182 (Bang) 2014 (Assessment Years : 2009 – 10)

For Appellant: Shri Mayank Jain & Shri Madhur Jain AdvocatesFor Respondent: Shri Sanjay Kumar, CIT DR
Section 143(3)Section 144CSection 144C(15)(b)Section 37(1)Section 92ASection 92A(1)Section 92A(2)Section 92B(2)

disallowed. 11. It should have been appreciated that no income has accrued and no addition could be made in respect of sale of land. The Appellant seeks your leave to add, alter, amend or delete any of the grounds urged at the time of hearing.” 3. In Para 1.2 of the assessment order, the A.O. has given the reasons

M/S UNITED SPIRITS LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR
Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

disallowance project spirit report. Rs.28,06,21,440 on DDT and interest of Rs.15,43,41,791 u/s 115P of the Act. 8. Grounds of appeal relating to short credit of 37,78,149 tax deducted at source / tax collected at source – Rs.37,78,149 9. Grounds of appeal relating to levy of 2,03,53,26,920 interest

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

disallowance made by the assessing officer could not be sustained.” 6. Considering the arguments from both the sides a similar issue has been decided by the co-ordinate bench of the Tribunal, therefore, respectfully following the above judgment in assessee’s own case for the AY 2015-16 cited supra in which the expenses incurred by the assessee have been

HP INDIA SALES PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LTU , BANGALORE

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

ITA 524/BANG/2017[2012-13]Status: DisposedITAT Bangalore18 Aug 2022AY 2012-13

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.524/Bang/2017 : Asst.Year 2012-2013 M/S.Hp India Sales Private The Joint Commissioner Of Limited (Formerly Known As Income-Tax, Ltu V. Bangalore. Hewlett-Packard India Sales Private Limited), 24 Salarpuria Area, Hosur Main Road, Adugodi Bangalore – 560 030. Pan : Aaacc9862F. (Appellant) (Respondent) Appellant By : Sri.Ajay Vohra, Senior Counsel / Sri. Neeraj Jain, Sri.Lalit Attal & Sri.Karon Dhanuka, Advoicates Respondent By : Sri.Harishchandra Naik, Cit-Dr Date Of Pronouncement : 18.08.2022 Date Of Hearing : 27.07.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 03.01.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2012-2013. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Import Of Computer Peripherals From Its Associated Enterprises (Aes) For Sale In India & Also Rendered Certain Support Services. The Return Of Income For Assessment Year 2012-2013 Was Filed On 29.02.2012, Admitting Total Income Of Rs.544,61,99,276. The Return Was Revised On 25.03.2014

For Appellant: Sri.Ajay Vohra, Senior Counsel / Sri. Neeraj JainFor Respondent: Sri.Harishchandra Naik, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 92BSection 92C

sections 92B(1) and 92F of the I.T.Act, contended 14 IT(TP)A No.524/Bang/2017. M/s.HP India Sales Private Limited. that the AMP expenditure is not an international transaction. It was also contended that even assuming for the sake of argument that though the AMP expenditure incurred by the assessee, results in an indirect benefit to the AE, no part

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

ITA 1899/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Aseem Sharma, CIT(DR)(ITAT), Bengaluru
Section 143Section 143(1)(a)Section 144CSection 37Section 40

disallowance. The DRP was also requested to delete the above adjustment, but it refrained from adjudicating the same. Over and above this issue, the other issues are with respect to the chargeability of interest under various provisions of the Act as well as initiation of penalty proceedings u/s. 270A of the Act. Page

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

In the result, the appeals filed by the assessee in IT(TP)A No

ITA 3376/BANG/2018[2014-15]Status: DisposedITAT Bangalore16 Nov 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.2889/Bang/2017 It(Tp)A No.3376/Bang/2018 Assessment Years: 2013-14 & 2014-15

For Appellant: Shri Percy Pardiwala, Sr. A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 143(3)

section 92F(v), an international transaction could include an arrangement, understanding or action in concert, this IT(TP)A No.2889/Bang/2017 & IT(TP)A No.3376/Bang/2018 M/s. Alcon Laboratories (India) Pvt. Ltd., Bangalore Page 12 of 49 could not be a matter of inference. There had to be some tangible evidence on record to show that two parties had acted in concert

ALCON LABORATORIES (INDIA0 PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

In the result, the appeals filed by the assessee in IT(TP)A No

ITA 2889/BANG/2017[2013-14]Status: DisposedITAT Bangalore16 Nov 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.2889/Bang/2017 It(Tp)A No.3376/Bang/2018 Assessment Years: 2013-14 & 2014-15

For Appellant: Shri Percy Pardiwala, Sr. A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 143(3)

section 92F(v), an international transaction could include an arrangement, understanding or action in concert, this IT(TP)A No.2889/Bang/2017 & IT(TP)A No.3376/Bang/2018 M/s. Alcon Laboratories (India) Pvt. Ltd., Bangalore Page 12 of 49 could not be a matter of inference. There had to be some tangible evidence on record to show that two parties had acted in concert

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 330/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Oct 2020AY 2010-11

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar
Section 139Section 143(3)Section 148

Section 92B r.w.s. 92F(v) it does not necessarily require transfer or assigning of property or creating any right or interest in the property but even an arrangement, understanding or an action in concert having a bearing on the profit, income, losses or assets of the enterprises would fall in the term of international transaction. Since the TPO has considered

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 804/BANG/2016[2011-12]Status: DisposedITAT Bangalore14 Oct 2020AY 2011-12

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar
Section 139Section 143(3)Section 148

Section 92B r.w.s. 92F(v) it does not necessarily require transfer or assigning of property or creating any right or interest in the property but even an arrangement, understanding or an action in concert having a bearing on the profit, income, losses or assets of the enterprises would fall in the term of international transaction. Since the TPO has considered

M/S NIKE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 3321/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Oct 2020AY 2014-15

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar
Section 139Section 143(3)Section 148

Section 92B r.w.s. 92F(v) it does not necessarily require transfer or assigning of property or creating any right or interest in the property but even an arrangement, understanding or an action in concert having a bearing on the profit, income, losses or assets of the enterprises would fall in the term of international transaction. Since the TPO has considered

M/S.NIKE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 739/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Oct 2020AY 2012-13

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar
Section 139Section 143(3)Section 148

Section 92B r.w.s. 92F(v) it does not necessarily require transfer or assigning of property or creating any right or interest in the property but even an arrangement, understanding or an action in concert having a bearing on the profit, income, losses or assets of the enterprises would fall in the term of international transaction. Since the TPO has considered

ALCON LABORATORIES (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

ITA 224/BANG/2021[2016-17]Status: DisposedITAT Bangalore19 Dec 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Percy Pardiwala, Sr. CounselFor Respondent: Shri K. Sankar Ganesh, Jt.CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 92C

section 92F(v), an international transaction could include an arrangement, understanding or action in concert, this could not be a matter of inference. There had to be some tangible evidence on record to show that two parties had acted in concert. It was also held that the provisions under Chapter X envisaged a separate entity concept. In other words, there

M/S. ACER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 502/BANG/2017[2012-13]Status: DisposedITAT Bangalore10 May 2019AY 2012-13

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

For Appellant: Shri Ajay Vohra, Sr. Advocate & Shri Niranjan, AdvocateFor Respondent: Dr. Pradeep Kumar, CIT (DR)
Section 143(3)Section 144C(13)Section 153Section 234BSection 271(1)(c)Section 40

Section 144C(13) gives extension of further period of one month from the date of receipt of direction from the DRP. In view of the above, the date of receipt of direction of DRP by the Assessing Officer becomes crucial......” 8. We notice that various benches of Tribunal are taking the view that the provisions of sec.144C(13) give extension

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

In the result, appeal of the assessee is partly allowed

ITA 202/BANG/2021[2015-16]Status: DisposedITAT Bangalore26 Jul 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.202/Bang/2021 Assessment Year :2015-16 M/S. Nike India Pvt.Ltd., Vs. Dcit, Ground & First Floor, Circle – 3(1)(1), Olympia Building, No.66/1, Bagmane Tech Bengaluru. Park, C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aabcn 9612 K Appellant Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Smt. Susan Dolores George, Cit(Osd)(Itat), Bengaluru. Date Of Hearing : 21.07.2022 Date Of Pronouncement : 26.07.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(ITAT), Bengaluru
Section 144(3)Section 92C

disallowed in various High Court Rulings. 3. The Learned AO / Learned TPO / Hon'ble DRP has erred in not accepting the order passed by the ITAT in its own case for AY 2009- 10 as well as the combined order of AY 2007-08, AY 2010-11 to AY 2014-15, wherein it was held that absence of an agreement