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4 results for “penalty u/s 271”+ Section 92B(1)clear

Sorted by relevance

Delhi54Mumbai20Kolkata10Hyderabad8Ahmedabad4Bangalore4Visakhapatnam3Jaipur2Chennai1

Key Topics

Section 92C4Transfer Pricing4Comparables/TP4Section 143(3)3Section 92C(3)3Section 37(1)2Natural Justice2TP Method2Disallowance

ASTRAZENECA PHARMA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

ITA 284/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Jun 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Sri Nikhil Tiwari, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 37Section 37(1)

penalty proceedings under section 274 read with section 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves to leave or add, alter, delete or modify all or any of the above grounds of appeal. 2. The assessee also raised additional grounds of appeal vide

M/S. ABB GLOBAL INDUSTRIES AND SERVICES PRIVATE LIMITED (EARLIER KNOWN AS ABB GLOBAL INDUSTRIES AND SERVICES LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

2

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

ITA 3/BANG/2020[2015-16]Status: DisposedITAT Bangalore17 Mar 2023AY 2015-16

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No. 03/Bang/2020 Assessment Year : 2015-16 M/S. Abb Global Industries & Services Pvt. Ltd. (Earlier Known As Abb The Deputy Global Industries & Commissioner Of Services Ltd.) Income Tax, 21St Floor, Wtc, Circle – 1(1)(1), Dr. Rajkumar Road, Bangalore. Vs. Malleshwaram, Bangalore – 560 055. Pan: Aadca3217B Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 01-03-2023 Date Of Pronouncement : 17-03-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 30.10.2019 Passed By The Ld.Dcit, Circle – 1(1)(1), Bangalore For A.Y. 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Here Under Are Independent Of & Without Prejudice To One Another: 1. Assessment Bad In Law At The Outset, Abb Global Industries & Services Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated 30Th October 2019

For Respondent: Smt. Tanmayee Rajkumar
Section 143(3)Section 92CSection 92C(3)

92B of the Act. 2.6 Treatment of provision no longer required as non- operating income for computing margin a) The TPO erred on facts in treating 'provisions no longer required written back' amounting to INR 2,00,00,000/- as a non-operating income though the provisions when originally made in earlier years were considered operating in nature while computing

LENOVO (INDIA) PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD- 4(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for above terms

ITA 281/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Mar 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Padam Chand Kincha, C.AFor Respondent: Shri Sankar K Ganeshan, CIT (D.R)
Section 143(3)Section 144C(13)Section 144C(5)Section 92CSection 92C(3)

92B of the Act, without appreciating that they had not incurred any expenditure on the directions of the AE. 16. The learned TPO erred in suo-moto benchmarking the alleged international transaction related to the AMP expenses without there being any order or reference from the AO in relation thereto. 17. The Honourable DRP and the learned AO / TPO have

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. THE ASSESSING OFFICER, NFAC, DELHI, BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 721/BANG/2021[2016-17]Status: DisposedITAT Bangalore16 Feb 2023AY 2016-17

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

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT (DR)
Section 92C

92B of the Act and failing to appreciate the fact that it is a routine business transaction and not per se a loan transaction. 8. That on the facts and circumstances of the case and in law, the AO/DRP/TPO have erred in charging notional interest on outstanding balance of debtors without appreciating that there was no delay in receipt