NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 54 of the Act. Further, without prejudice, the assessee had furnished possession certificate dated 01/05/2018 for having occupied the property and hence sought relief for deduction u/s. 54 of the Act. However, as per the provisions of the Act the assessee should purchase a new residential property within two years from the date of sale and thus

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

house properties were already in the file or that the decision subsequently come across by him was already there would not affect the position because the information that such facts or decision existed comes to him only much later. What then, is the difference between the situations envisaged in propositions (2) and (4) of Kalyanji Maviji's case

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

144C(13) r.w.s 144(B) of the Income Tax Act, 1961 wherein the returned income of the Assessee at Rs. Nil/- is assessed at a loss of Rs. 161,63,03,274/-. The Assessee is aggrieved with that and is in appeal before us. ITA Nos. 261 & 777/Bang/2022 Page 2 of 18 2. In the Assessment Order, there

VIJAY LAKHMICHAND ISRANI,MUMBAI vs. ACIT, INTERNATIONAL TAXATION, CIRCLE-1(2), BANGALORE

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

144C (13) of the Act dated 22.01.2025, the assessee has filed the present appeal before this Tribunal. Before us, the assessee has also filed statement of facts, grounds of appeal along with the written submissions. 6. We have heard ld. Department Representative Dr. Divya.K.J., CIT and perused the material available on record. The assessee being a senior citizen non-resident

NISHA VIJAY ISRANI,MUMBAI vs. ACIT, INTERNATIONAL TAXATION, CIRCLE-1(2), BANGALORE

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

144C (13) of the Act dated 22.01.2025, the assessee has filed the present appeal before this Tribunal. Before us, the assessee has also filed statement of facts, grounds of appeal along with the written submissions. 6. We have heard ld. Department Representative Dr. Divya.K.J., CIT and perused the material available on record. The assessee being a senior citizen non-resident

M/S. HIMALAYA WELLNESS COMPANY (FORMERLY KNOWN AS THE HIMALAYA DRUG COMPANY),BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(1), BENGALURU

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.259/Bang/2022 : Asst.Year 2017-2018 M/S.Himalaya Wellness Company The Deputy Commissioner Of (Formerly Known As The Himalaya Income-Tax, Circle 6(1)(1) V. Bengaluru. Drug Company), Makali, Tumkur Road Bengaluru – 562 162. Pan : Aadft3025B. (Appellant) (Respondent)

properties owned by the Appellant by failing to appreciate that such registrations are obtained in compliance with the statutory preconditions for sale of the products. 11.5 The Lower Authorities have failed to appreciate that the alleged associated enterprises are acting as distributors and are paying the purchase consideration to the appellant in respect thereof leaving nothing else to be paid

RAVIKUMAR TIRUPATI PARTHASARATHY,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), BANGALORE

In the result, the appeal is allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2019-20

Housing Complex, of Income Tax, Arekere Layout, Circle 2(1), Bannerghatta Road, Bangalore. Bangalore – 560 076. PAN: AENPR 7573N APPELLANT RESPONDENT Appellant by : Shri Arjun Raj, CA Respondent by : Shri K. Sankar Ganesh, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 27.10.2022 Date of Pronouncement : 28.10.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144C(13) read with section 144B of the Act. The AO confirmed the additions proposed in the DAO as per the directions of the DRP. The AO accordingly assessed the income of the assessee at Rs.640,40,30,225/- against the income of Rs.461,47,05,660/- declared by the assessee in its returned income. The assessee being aggrieved

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144C(13) read with section 144B of the Act. The AO confirmed the additions proposed in the DAO as per the directions of the DRP. The AO accordingly assessed the income of the assessee at Rs.640,40,30,225/- against the income of Rs.461,47,05,660/- declared by the assessee in its returned income. The assessee being aggrieved

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

House, Barrow Street,\nDublin.]\nC/o. AZB & Partners,\n7th Floor, Embassy Icon,\nInfantry Road,\nBengaluru - 560 001.\nPAN: AADCG 7672A\nAPPELLANT\nRESPONDENT\nAppellant by\n: Shri Deepak Chopra, Ms. Priya Tandon, Shri\nAnmol Anand, Sri Aadith Sridhar, Advocates.\nRespondent by\n: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru.\nDate of hearing\n: 21.03.2024\nDate of Pronouncement : 26.03.2024\nORDER\nThese appeals

GOOGLE IRELAND LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, (IT), CIRCLE-1(1), BENGALURU

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

Bench: Shri George George K. & Ms. Padmavathy S.It(It)A No. 2845/Bang/2017 (Assessment Year: 2007-08)

houses to promote their products and services via targeted advertising. The AO on verification of financial statement of GIPL noticed that it had credited an amount of Rs.42,57,53,347/- to the account of the assessee during the relevant assessment year without deducting tax at source under Section 195 of the Act. Further it was noticed

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144C(5). On the facts and in the circumstances of the case and in law, the Ld. c) Panel and Ld. AO/ Ld. TPO erred in not demonstrating that the motive of the Appellant was to shift profits outside India by manipulating the prices charged in the international transaction, which is a pre- requisite condition to make any adjustment under

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

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

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

property ("IP") (i.e. technical know-how developed and maintained by the group companies). 26. The learned AO has erred in concluding that there is no rationale for making royalty payment in addition to capital expenditure incurred on technical know-how provided by the AE, without appreciating that these two are distinct transactions and the Appellant has substantiated the business rationale

CHARLES RIVER LABORATORIES INC.,UNITED STATES vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(1), BANGALORE

In the result, all the three appeals filed by the assessee stands allowed

144C of the Income Tax Act. 1961 (" the Act") for the captioned Assessment Year ("AY"). Each of the ground is referred to separately, which may be kindly considered independent of each other. 1. Ground 1: Income earned by the Appellant erroneously characterized to be in the nature of Fees for Included Services/ Fees for Technical Services under

CHARLES RIVER LABORATORIES INC.,UNITED STATES vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(1), BANGALORE

In the result, all the three appeals filed by the assessee stands allowed

144C of the Income Tax Act. 1961 (" the Act") for the captioned Assessment Year ("AY"). Each of the ground is referred to separately, which may be kindly considered independent of each other. 1. Ground 1: Income earned by the Appellant erroneously characterized to be in the nature of Fees for Included Services/ Fees for Technical Services under

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144C(13) of the Act. The AO confirmed the additions proposed in the draft assessment order as per the directions of the DRP. 2.5 The AO accordingly assessed the income of the assessee at Rs.429,75,39,850/- against the income of Rs.349,75,85,670/- declared by the assessee in its returned income. 2.6 The assessee being aggrieved

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

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

House, Barrow Street, Circle 1(1), Dublin.] Bengaluru. C/o. AZB & Partners, 7th Floor, Embassy Icon, Infantry Road, Bengaluru – 560 001. PAN: AADCG 7672A APPELLANT RESPONDENT Appellant by : Shri Deepak Chopra, Ms. Priya Tandon, Shri Anmol Anand, Sri Aadith Sridhar, Advocates. Respondent by : Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru. Date of hearing : 21.03.2024 Date of Pronouncement

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

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

House, Barrow Street, Circle 1(1), Dublin.] Bengaluru. C/o. AZB & Partners, 7th Floor, Embassy Icon, Infantry Road, Bengaluru – 560 001. PAN: AADCG 7672A APPELLANT RESPONDENT Appellant by : Shri Deepak Chopra, Ms. Priya Tandon, Shri Anmol Anand, Sri Aadith Sridhar, Advocates. Respondent by : Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru. Date of hearing : 21.03.2024 Date of Pronouncement

M/S HARMAN INTERNATIONAL (INDIA) PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

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

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.49/Bang/2019 Assessment Year : 2014-15 M/S. Harman Connected Services Vs. Deputy Commissioner Of Corporation India Private Limited, Income Tax, 4A, Jupiter, Prestige Technology Park, Circle - 3(1)(2), Sarjapur, Marathahalli Road, Bengaluru. Kadubeesanahalli Village, Bengaluru – 560 103. Pan: Aacch 1585 J Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 27.06.2022 Date Of Pronouncement : 30.06.2022 O R D E R Per N V Vasudevan

section 144C of the Act. 12. The DRP issued the following directions to the TPO: IT(TP)A No. 49/Bang/2019 Page 5 of 31 The following companies were directed by the DRP to be excluded from the list of comparables by accepting the contentions of the assessee: (i) Cigniti Technologies Ltd.; and (ii) SQS India