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.

70 results for “house property”+ Section 92C(3)clear

Sorted by relevance

Mumbai171Delhi131Bangalore70Ahmedabad52Kolkata48Chennai14Pune12Hyderabad10Indore8Jaipur7Surat6SC2Karnataka1

Key Topics

Section 143(3)61Transfer Pricing58Section 92C57Section 10A52Comparables/TP50Addition to Income49Depreciation17Disallowance17Deduction17

M/S DELL INTERNATIONAL SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal is allowed

ITA 879/BANG/2018[2007-08]Status: DisposedITAT Bangalore24 Jun 2020AY 2007-08

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Muzzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 144CSection 92Section 92C

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” ii. As per the Notes to Accounts - Schedule 15, under “Deferred Revenue Expenditure” (page 31 of PB-II), it is mentioned that, “Expenditure incurred on research and development of new products has been treated as deferred revenue expenditure and the same has been written

M/S. THE HIMALAYA DRUG COMPANY,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

Showing 1–20 of 70 · Page 1 of 4

Section 133(6)15
TP Method14
Section 9213

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

ITA 2248/BANG/2016[2012-13]Status: DisposedITAT Bangalore02 Nov 2020AY 2012-13

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

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 143(3)Section 144C(1)Section 156

92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :— "(c) cost plus method, by which,— (i) the direct and indirect costs of production incurred by the enterprise in respect of property transferred

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

92C(3) based on ‘enhanced’ income. We therefore find merit in the arguments advanced by the Ld.Counsel in this regards. 45. The Ld.Counsel before us submitted that assessee does not have any other income other than the income generated from the units that is eligible for deduction under section 10A of the Act. It is also been submitted that

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

ITA 2532/BANG/2019[2015-16]Status: DisposedITAT Bangalore19 May 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai for Shri K.R. VasudevanFor Respondent: Shri Sankar Ganesh K., D.R
Section 143(3)Section 144C(13)Section 14ASection 37Section 92C

92C(2).” 11.1 Facts of the case are that the Assessee entered into sponsorship agreement dated 23.06.2015 with United East Bengal Football Team Private Limited (“UEBFT”) for sponsorship fee of IT(TP)A No.2532/Bang/2019 United Brewries Ltd., Bangalore Page 17 of 70 Rs.9,25,00,000/- for promotion of “United Breweries Brand” and “Kingfisher Brand”. In terms of the agreement

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

ITA 345/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Aug 2023AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

92C(2). 7.1 The crux of above grounds is with regard to disallowance on payment of royalty. 7.2 After hearing both the parties, we are of the opinion that similar issue came for consideration in assessee’s own case in IT(TP)A IT(TP)A No.345/Bang/2021 & M/s. United Breweries Ltd., Bangalore Page 14 of 50 No.2569/Bang/2017 dated 1.6.2022 wherein

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

ITA 308/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Aug 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

92C(2). 7.1 The crux of above grounds is with regard to disallowance on payment of royalty. 7.2 After hearing both the parties, we are of the opinion that similar issue came for consideration in assessee’s own case in IT(TP)A IT(TP)A No.345/Bang/2021 & M/s. United Breweries Ltd., Bangalore Page 14 of 50 No.2569/Bang/2017 dated 1.6.2022 wherein

MINDTECK (INDIA) LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, appeal by the Assessee is partly allowed

ITA 1548/BANG/2010[2006-07]Status: DisposedITAT Bangalore09 Jan 2015AY 2006-07

Bench: Shri N.V. Vasudevan & Shri Abraham P. George

For Appellant: Shri Raghunathan, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 133(6)Section 143(3)Section 92CSection 92E

property transferred or services provided in either transaction; (b) the functions performed, taking into account assets employed or to be employed and the risks assumed, by the respective parties to the transactions; (c) the contractual terms (whether or not such terms are formal or in writing) of the transactions which lay down explicitly or implicitly how the responsibilities, risks

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)

92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :- “(c)cost plus method, by which,— (i)the direct and indirect costs of production incurred by the enterprise in respect of property transferred

MFX INFOTECH PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BANGALORE

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

ITA 251/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 133(6)Section 143(3)Section 144B

House, Sarjapur BMTC Building, 80 Feet Road Ambalipura Road 6th Block, Koramangala Bengaluru 560095 Bellandur Gate Bengaluru 560102 PAN – AAJCM2530P (Appellant) (Respondent) Assessee by: Shri Padamchand Kincha, CA Revenue by: Shri Manjunath Karkihalli, CIT-DR Date of hearing: 27/09/2022 Date of pronouncement: 21/10/2022 O R D E R Per: Padmavathy, A.M. This appeal is against the final assessment order passed

ANALOG DEVICES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 38/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Jun 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.38/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Kannan Narayanan, JCIT
Section 250

92C(2) of the Act; 3. The learned CIT(A) has erred, in law and facts, in confirming the imposition of interest under Sections 234B and 234D of the Act by the learned AO 4. The learned CIT(A) has erred, in law and facts, in upholding initiation of penalty proceedings under section

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

ITA 319/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

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)

Section 143(3)Section 144C(13)Section 92C(3)

92C(2) to the Appellant. 8. Non set-off of the entire brought forward losses a) That, after having made the transfer pricing adjustments and without prejudice to our contention that no adjustment should be made to the returned income, the AO erred in not setting-off the remaining brought forward Page

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

ITA 280/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

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)

Section 143(3)Section 144C(13)Section 92C(3)

92C(2) to the Appellant. 8. Non set-off of the entire brought forward losses a) That, after having made the transfer pricing adjustments and without prejudice to our contention that no adjustment should be made to the returned income, the AO erred in not setting-off the remaining brought forward Page

THE HIMALAYA DRUG COMPANY,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CIRCLE-6(1)(1), BENGALURU

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

ITA 303/BANG/2021[2016-17]Status: DisposedITAT Bangalore22 Oct 2021AY 2016-17

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

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Muzaffar Hussain, D.R
Section 143(3)

92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :— "(c) cost plus method, by which,— (i) the direct and indirect costs of production incurred by the enterprise in respect of property transferred

AMD INDIA PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeal of the Assessee is partly allowed

ITA 1244/BANG/2011[2007-08]Status: DisposedITAT Bangalore23 Sept 2015AY 2007-08

Bench: Shri N.V. Vasudevan & Shri Abraham P. George

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri G.R.Reddy, CIT-I(DR)
Section 10ASection 143(3)Section 144Section 92CSection 92C(2)Section 92D

92C(2) of the Act) range of the arithmetical mean of the comparables, the international transactions of the Appellant were claimed by the Assessee to be at arm’s length. 3. The financial results of the assessee in its software development services segment were as follows:- Description Amount (Rs.) Operating revenues 40,12,49,022 Operating Expenditure

M/S. LSI TECHNOLOGIES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result, both the appeals are partly allowed

ITA 1380/BANG/2010[2006-07]Status: DisposedITAT Bangalore13 May 2016AY 2006-07

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Respondent: Ms. Neera Malhotra, CIT(DR)
Section 144Section 92CSection 92C(3)

Property Rights (IPRs). This company is not only into software products as explained in the Annual Report of this company but also is engaged in the embedded product development based on current and emerging technologies such as Multi- media, Wimax, Imaging, Imaging Process etc. The company actively engaged in developing house expertise in current and emerging markets through house development

THE HIMALAYA DRUG COMPANY ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE

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

ITA 3071/BANG/2018[2014-15]Status: DisposedITAT Bangalore07 Dec 2020AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

For Appellant: ShriFor Respondent: Shri Pradeep Kumar, CIT-D.R
Section 143(3)

92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :— "(c) cost plus method, by which,— (i) the direct and indirect costs of production incurred by the enterprise in respect of property transferred

M/S. THE HIMALAYA DRUG COMPANY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(2)(1), BENGALURU

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

ITA 2434/BANG/2019[2015-16]Status: DisposedITAT Bangalore08 Dec 2020AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2015-16

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 234B

92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :— "(c) cost plus method, by which,— (i) the direct and indirect costs of production incurred by the enterprise in respect of property transferred

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

property of Jockey and Jockey shall be entitled to use the same and to license the use of the same to others. The Agreement started on January 1, 2005 and expires on December 31,2009. S per term S8 of the schedule to the agreement the target of minimum sales have been fixed for each year. For instance

M/S. E4E BUSINESS SOLUTIONS INDIA PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, BANGALORE

In the result, the assessee’s appeal for asst

ITA 451/BANG/2017[2012-13]Status: DisposedITAT Bangalore03 Nov 2017AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazit(Tp)A No.451/Bang/2017 (Assessment Year : 2012-13) M/S. E4E Business Solutions India Pvt. Ltd., 5Th Floor, Vakil Square, Bannerghatta Road, Bengaluru. ……. Appellant Pan – Aaaci 6324A. Vs. The Income-Tax Officer, Ward 2(1)(2), Bengalore. …………..Respondent

For Appellant: Shri Ravindra T, C.AFor Respondent: Shri R.N. Parbat, CIT-III (D.R)
Section 115JSection 143(3)Section 144C(5)Section 92CSection 92C(3)(c)Section 92D

3) Datamatics Financial Services Ltd., and 4) ICRA Techno Analytics Ltd., We shall now proceed to examine the comparability of the above mentioned companies. 9 Accentia Technologies Ltd., (‘Accentia’) 9.1 This company was selected as a comparable by the TPO, overruling the objections of the assessee to its inclusion on grounds of it being functionally different from the assessee

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

property of assessee and Spreadtrum under the Settlement Agreement. This is clear from the term "Independently Owned IPR" as understood under the Settlement Agreement which means background IPR which in turn means that is owned or controlled by a party existing prior to the beginning of the joint development project or resulting from activities which are independent from and concurrent