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.

165 results for “house property”+ TP Methodclear

Sorted by relevance

Mumbai218Delhi201Bangalore165Kolkata69Ahmedabad50Chennai25Jaipur16Hyderabad13Pune8Surat6Karnataka3Indore3SC2Kerala1Telangana1

Key Topics

Transfer Pricing74Section 10A60Addition to Income56Section 143(3)49Comparables/TP49Section 92C46Deduction33Disallowance27Section 4025

DEV KUMAR ROY ,BANGALORE vs. INCOME TAX OFFICER WARD-3(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 2350/BANG/2018[2012-13]Status: DisposedITAT Bangalore05 Feb 2019AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Jason P Boazassessment Year : 2012-13

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Shri Pradeep Kumar, CIT
Section 54FSection 56(2)(vii)

TP Act, 1882 and GT Act, 1958 and a company can make a gift to another company, which is valid in law. Accordingly, we accept the legal capacity of the assessee company to gift its shares in RGF Gulf to Rh-IL Cayman.” 24. The Hon’ble Karnataka High Court in the case of CIT Vs. Nadatur Holdings and Investments

GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the revenue’s appeal is dismissed and the assessee’s appeal is partly allowed

Showing 1–20 of 165 · Page 1 of 9

...
Section 234B22
Section 14A17
TP Method17
ITA 332/BANG/2011[2004-05]Status: DisposedITAT Bangalore30 Jun 2015AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

For Appellant: Shri K.R.Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 92C

property to GEMS India. which is used in manufacturing process for which royalty is paid and GEMS India is remunerated on a cost plus method but has the leverage to increase the margins by saving on costs. Thus GEMS India is a contract manufacturer whose pricing decisions are controlled by the affiliate. In its TP study, the assessee adopted

DCIT, BANGALORE vs. M/S GE MEDICAL SYSTEM (I) (P) LIMITED, BANGALORE

In the result, the revenue’s appeal is dismissed and the assessee’s appeal is partly allowed

ITA 337/BANG/2011[2004-05]Status: DisposedITAT Bangalore30 Jun 2015AY 2004-05

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

For Appellant: Shri K.R.Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 92C

property to GEMS India. which is used in manufacturing process for which royalty is paid and GEMS India is remunerated on a cost plus method but has the leverage to increase the margins by saving on costs. Thus GEMS India is a contract manufacturer whose pricing decisions are controlled by the affiliate. In its TP study, the assessee adopted

GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the revenue’s appeal is dismissed and the assessee’s appeal is partly allowed

ITA 333/BANG/2011[2005-06]Status: DisposedITAT Bangalore30 Jun 2015AY 2005-06

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

For Appellant: Shri K.R.Vasudevan, AdvocateFor Respondent: Shri C.H.Sundar Rao, CIT(DR)
Section 10ASection 143(3)Section 92C

property to GEMS India. which is used in manufacturing process for which royalty is paid and GEMS India is remunerated on a cost plus method but has the leverage to increase the margins by saving on costs. Thus GEMS India is a contract manufacturer whose pricing decisions are controlled by the affiliate. In its TP study, the assessee adopted

M/S. G. R. DEVELOPERS,BANGALORE vs. ACIT, BANGALORE

In the result, the appeal of the assessee is dismissed

ITA 1439/BANG/2010[2007-08]Status: DisposedITAT Bangalore03 Mar 2017AY 2007-08

Bench: Shri A.K Garodiashri Laliet Kumarg.R Developers, 142-143, 1St Floor, Gr Plaza, D.V.G Road, Basavanagudi, Bangalore-. . Appellant Pan No.Aaefg3522F. Vs. The Asst. Commissioner Of Income-Tax, Circle-3(1), Bangalore. . Respondent * Appellant By : Shri K.R Pradeep, C.A Assessee By : Shri M.K Biju, Jcit Date Of Hearing : 02-02-2017 Date Of Pronouncement : 03-03-2017

For Appellant: Shri K.R Pradeep, C.A Assessee by : Shri M.K Biju, JCIT
Section 234BSection 8

method of accounting and states that in case of business income, inter alia, the same is to be computed in accordance with the cash or mercantile system of accounting. Sub-section (2) thereof IT(TP)A No.1439/B/10 15 authorizes the Central Government to notify in the Official Gazette from time to time accounting standards to be followed by any class

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

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)

method of classification of companies by size. It was submitted that the 3 categories of firms were identified that is small with turnover less than 200 crore, medium with turnover Rs. 200 to 2000 crore and large with turnover greater than 2000 crore. The Ld.AR further submitted that, ITAT Mumbai Tribunal in case of Capgemini India Pvt.Ltd., vs ACIT reported

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

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)

house after framing has been erected. 3. From the above analysis, it can be seen that a company which develops a software product by following all the above steps involved in creating a software is a software development company and in this case, intellectual property generated belongs to the company and the products are generally sold on license basis wherein

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)

house after framing has been erected. 3. From the above analysis, it can be seen that a company which develops a software product by following all the above steps involved in creating a software is a software development company and in this case, intellectual property generated belongs to the company and the products are generally sold on license basis wherein

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 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)

house comparables. In absence of internal comparables, the taxpayer can and would need to rely upon external comparables, 1e comparable transactions by independent enterprises. For several reasons, database providers, it is apparent, have the requisite information and data of external comparables to enable comparability analysis of the controlled and adjustment to obtain reliable results under TNM Method. This method also

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)

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; IT(TP)A No.3071/Bang/2018 The Himalaya Drug Company, Bangalore Page 26 of 75 (c) the contractual terms (whether or not such terms are formal or in writing

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

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

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)

house comparables. In absence of internal comparables, the taxpayer can and would need to rely upon external IT(TP)A No.303/Bang/2021 & SP No.64/Bang/2021 M/s. The Himalaya Drug Company, Bangalore Page 22 of 47 comparables, i.e. comparable transactions by independent enterprises. For several reasons, database providers, it is apparent, have the requisite information and data of external comparables to enable comparability

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

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. GMR ENTERPRISES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(2), BANGALORE

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

ITA 2310/BANG/2019[2015-16]Status: DisposedITAT Bangalore28 Oct 2021AY 2015-16

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am It(Tp)A No.2310/Bang/2019 : Asst.Year 2015-2016 M/S.Gmr Enterprises Pvt. Ltd. The Dy.Commissioner Of (Successor To Gmr Holdings P.Ltd) Income-Tax, Central Circle 2(2) V. Bangalore. No.25/1 Skip House, Museum Rd. Bangalore – 560 025. Pan : Aaccr1554R. (Appellant) (Respondent) Appellant By : Sri.Yogesh Thar, Ca Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 28.10.2021 Date Of Hearing : 25.10.2021 O R D E R Per Bench:- This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 14.10.20199 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2015-2016. 2. The Assessee Has Raised Five Grounds & Various Sub Grounds. The Assessee By Its Application Dated 13.07.2020 Has Also Raised An Additional Ground. The Learned Ar During The Course Of Hearing Submitted That Grounds No.Ii & Iii May Be Adjudicated & The Other Grounds May Be Left Open. Therefore, Grounds No.Ii & Iii Are Reproduced Below:-

For Appellant: Sri.Yogesh Thar, CAFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 142ASection 143(3)Section 14ASection 56(2)(viib)

Housing Development Corporation Ltd. v. ACIT in Writ Petition (C) No.4554 of 2011, held that an error or omission can be rectified only filing a revised return within the prescribed time limit u/s 139(5) of the I.T.Act. Therefore, it was concluded by the DRP that the assessee is not entitled to raise such a claim before the Assessing Officer

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

ITA 954/BANG/2022[2018-19]Status: DisposedITAT Bangalore22 Feb 2023AY 2018-19

Bench: Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 234Section 255Section 255(3)Section 36

method of accounting mandated under section 145(2), the assessee has to follow the principles laid down in the 1GDS. 5.2 Further, the ld. A.R. submitted that in case of the assessee, as it is a company, it has to mandatorily follow Accounting Standard for preparations of its accounts under the Companies Act, 2013 and follow the ICDS for computation

SAMI-SABINSA GROUP LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

ITA 184/BANG/2022[2017-18]Status: DisposedITAT Bangalore07 Nov 2022AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri K.P. Srinivas, A.RFor Respondent: Shri Sunil Kumar Singh, DR
Section 234ASection 35(1)(i)

Method of determination of ALP of international transactions for its proficiency, convenience and reliability and in TNMM preference should be internal or in-house comparables. 25. Based on the above referred judicial precedents including in the Appellant’s own case for AY 2013-14 and AY 2014-15, we request this Hon’ble Bench to direct the TPO to consider