HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

house property of Rs.59,535/- and interest from deposits in banks of Rs.60,557/- along with NIL capital gains after claim of cost of acquisition & deduction u/s 54 of the Act. The assessee in his computation of income had also claimed deduction u/s 80TTA of the Act and thus declared total income of Rs.1,10,090/-.The AO while completing

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

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

3 of 14 a) Received amount of Rs.70,00,000/- for sale of immovable property. b) Paid purchase consideration Rs.21,26,423/- for purchase of immovable property to Bhartiya Urban Private Limited. After obtaining the prior approval of the CIT (Intl. Taxation), Bengaluru on 29/03/2023, the order u/s. 148A(d)of the Act along with the notice

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

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

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

3) r.w.s 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

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

3) r.w.s 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

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

144C of the Income Tax Act, 1961 (“the Act”). 3. The Appellant filed its objections before the DRP which issued its directions on 30.12.2013. In line with the DRP directions, the Assessing Officer (‘AO’) passed the final assessment order u/s. 143(3) r.w.s.144C of the Act on 30.01.2014 computing the loss at INR 48,29,16,189/-. Aggrieved, both

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. 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

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

RAHUL MEKA ,BENGALURU vs. INCOME TAX OFFICER, WARD INTERNATIONAL TAXATION-1(2) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

property in a new residential house is eligible for claim of exemption under section 54 F of the Act, and ought to have given all the benefits and exemptions available as per the statute, on the facts and circumstances of the case. 5. Without prejudice, to the right to seek waiver as per the parity of reasoning of the decision

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

ITO WARD - 5(1)(1), BANGALORE vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT. LTD.,, BANGALORE

In the result, appeal filed by assessee stands allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 280/Bang/2016 Assessment Year : 2011-12 M/S. Micro Focus Software India Pvt. Ltd. (Earlier Known As Novell Software Development The Income Tax (India) Pvt. Ltd.), Officer, Bagmane Tech Park ‘D’ Ward – 4 (1)(3), Block, Bangalore. ‘Laurel’ 65/2, Vs. C V Raman Nagar, Byrasandra, Bangalore – 560 093. Pan: Aaacn6992K Appellant Respondent & It(Tp)A No. 319/Bang/2016 Assessment Year : 2011-12 (By Assessee) : Smt. Tanmayee Rajkumar, Assessee By Advocate : Dr. Manjunath Karkihalli, Cit Revenue By (Dr) Date Of Hearing : 03-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Cross Appeals Has Been Filed By Revenue As Well As Assessee Against Order Dated 29.12.2015 Passed By Ld.Ito Ward 5(1)(1)

144C(13) of the Act, for assessment year 2011-12 on following grounds of appeal: Revenue’s appeal “1. The directions of the Dispute Resolution Panel are opposed to the law and not on the facts and circumstance of the case. 2. The ld.DRP erred in holding that the size and turnover of the company are deciding factors for treating

NOVELL SOFTWARE DEVELOPMENT (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, appeal filed by assessee stands allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 280/Bang/2016 Assessment Year : 2011-12 M/S. Micro Focus Software India Pvt. Ltd. (Earlier Known As Novell Software Development The Income Tax (India) Pvt. Ltd.), Officer, Bagmane Tech Park ‘D’ Ward – 4 (1)(3), Block, Bangalore. ‘Laurel’ 65/2, Vs. C V Raman Nagar, Byrasandra, Bangalore – 560 093. Pan: Aaacn6992K Appellant Respondent & It(Tp)A No. 319/Bang/2016 Assessment Year : 2011-12 (By Assessee) : Smt. Tanmayee Rajkumar, Assessee By Advocate : Dr. Manjunath Karkihalli, Cit Revenue By (Dr) Date Of Hearing : 03-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Cross Appeals Has Been Filed By Revenue As Well As Assessee Against Order Dated 29.12.2015 Passed By Ld.Ito Ward 5(1)(1)

144C(13) of the Act, for assessment year 2011-12 on following grounds of appeal: Revenue’s appeal “1. The directions of the Dispute Resolution Panel are opposed to the law and not on the facts and circumstance of the case. 2. The ld.DRP erred in holding that the size and turnover of the company are deciding factors for treating

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

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