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

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

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

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)

92D and 92E of the Income Tax Act and it remains an arbitrary, artificial and unsubstantiated figure.” 31. The Ld.Counsel submitted that, in the original return filed by assessee revenue of Rs.37,01,58,923/- was shown to be the Page 21 of 55 IT(TP)A No.517 & 570/Bang/2015 value of international transaction for software development services, with an operating

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

92D, the Assessing Officer may proceed to determine the arm’s length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him:” 18. Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm’s length price under section

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

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

SOFTWARE AG BANGALORE TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

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

ITA 1306/BANG/2011[2007-08]Status: DisposedITAT Bangalore30 Sept 2015AY 2007-08

Bench: Shri N. V. Vasudevan & Shri.Abraham P.Georgeit(Tp)A No.1306/Bang/2011 Assessment Year : 2007-08

For Appellant: Shri Chavali Naryana, CAFor Respondent: ShrI G.R. Reddy, CIT(DR-I)

Section 10ASection 143(3)Section 92

house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act.” IT(TP)A No.1306/Bang/2011 Page 15 of 51 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

M/S. ARM EMBEDDED TECHNOLOGIES PVT. LTD,BANGALORE vs. DCIT,, BANGALORE

In the result, both the appeals are partly allowed for statistical purposes

ITA 1112/BANG/2010[2006-07]Status: DisposedITAT Bangalore01 Dec 2015AY 2006-07

Bench: Smt. Asha Vijayaraghavan & Shri Abraham P. George

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri I.P.S. Bindra, CIT(DR-I)

Section 10ASection 143(3)Section 92C

92D, the Assessing Officer may proceed to determine the arm’s length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him:” 18. Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm’s length price under section

M/S ARM EMBEDDED TECHNOLOGIES PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals are partly allowed for statistical purposes

ITA 1161/BANG/2011[2007-08]Status: DisposedITAT Bangalore01 Dec 2015AY 2007-08

Bench: Smt. Asha Vijayaraghavan & Shri Abraham P. George

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri I.P.S. Bindra, CIT(DR-I)

Section 10ASection 143(3)Section 92C

92D, the Assessing Officer may proceed to determine the arm’s length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him:” 18. Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm’s length price under section

BROADCOM INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

ITA 1164/BANG/2011[2007-08]Status: DisposedITAT Bangalore11 Jun 2015AY 2007-08

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

For Appellant: Ms. Shreya Loyalka, CA

Section 143(3)Section 92

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

BROADCOM COMMUNICATIONS TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

ITA 1276/BANG/2011[2007-08]Status: DisposedITAT Bangalore11 Jun 2015AY 2007-08

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

For Appellant: Ms. Shreya Loyalka, CA

Section 143(3)Section 92

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

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

In the result, appeal by the Assessee is partly allowed

ITA 1082/BANG/2011[2007-08]Status: DisposedITAT Bangalore14 May 2015AY 2007-08

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

For Appellant: Shri Sampath Raghunathan, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)

Section 143(3)Section 234ASection 271(1)Section 92CSection 92E

92D, the Assessing Officer may proceed to determine the arm’s length price in relation to the said international transaction in accordance with sub-sections (1) and (2), on the basis of such material or information or document available with him:” 18. Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm’s length price under section

BROADCOM INDIA RESEARCH PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

ITA 1180/BANG/2011[2007-08]Status: DisposedITAT Bangalore28 Jan 2015AY 2007-08

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

For Appellant: Shri Sreeram Seshadri, AdvocateFor Respondent: Shri.C.H. Sundar Rao, CIT-I (DR)

Section 143(3)Section 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. FIRST APEX SOFTWARE TECHNOLOGIES PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

ITA 1311/BANG/2010[2006-07]Status: DisposedITAT Bangalore20 Mar 2015AY 2006-07

Bench: Shri. N. V. Vasudevan & Shri. Jason P.Boazi.T(Tp).A No.1311/Bang/2010 (Assessment Year : 2006-07)

For Appellant: Shri. Rishi Harlalkar, C.AFor Respondent: Shri.Farhat Hussain Qureshi, CIT (DR)

Section 143(3)Section 92Section 92C

House, 106, Amarjyothi Layout, Off Intermediate Ring Road, Domlur, Bangalore 560 071. Appellant PAN : AAACF9123A Vs. Deputy Commissioner of Income Tax, Circle 11(3), Bangalore Respondent Appellant by : Shri. Rishi Harlalkar, C.A. Respondent by : Shri.Farhat Hussain Qureshi, CIT (DR) Heard on : 18.03.2015 Pronounced on : 20 .03.2015 O R D E R PER N. V. VASUDEVAN, JUDICIAL MEMBER : This appeal

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 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)

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. 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

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)

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

EMC SOFTWARE AND SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 2, BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes as per the terms mentioned above

ITA 191/BANG/2021[2016-17]Status: DisposedITAT Bangalore27 Mar 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT (D.R)

Section 133(6)Section 143(3)Section 144C(13)Section 92D

92D(3) of the Act. From the documents submitted, the ld.TPO noticed that the assessee company is IT(TP)A No.191/Bang/2021 Page 6 of 61 engaged in developing, delivering and supporting the information technology. 2.1 On perusal documents submitted by the assessee, the functional profile was observed by the TPO as under:- “2. FUNCTIONAL ANALYSIS OF THE TAXPAYER

M/S.LM WIND POWER TECHNOLOGIES (INDIA) PVT., LTD.,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

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

ITA 1692/BANG/2016[2012-13]Status: DisposedITAT Bangalore29 Nov 2019AY 2012-13

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr.P.V.Pradeep Kumar, Addl.CIT

Section 92CSection 92C(3)

section 92D of the Act. IT(T)A No.1692(B)/2016 6 Ld.TPO observed that assessee develops and manufactures blades for wind turbines both small onshore wind turbines and large turbines in offshore wind farms. It was observed that assessee develops technology and products with new capabilities to monitor operations, protect against lightening strikes and ensure maximum energy production

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)

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