NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

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

reassessment proceedings. He submitted that the assessee had furnished all the relevant details to the AO during the course of original assessment proceedings and hence, there is no failure as contemplated in the proviso to sec. 147 of the Act. The Ld. A.R. further submitted that the Hon’ble Karnataka High Court has held in the case

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

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

reassessment proceedings. He submitted that the assessee had furnished all the relevant details to the AO during the course of original assessment proceedings and hence, there is no failure as contemplated in the proviso to sec. 147 of the Act. The Ld. A.R. further submitted that the Hon’ble Karnataka High Court has held in the case

M/S. ACER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, both the appeals of the assessee are partly allowed

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

reassessment order passed by the Assessing Officer with the prior approval of the Commissioner under sub- section (12) of section 144BA. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board 5 for this purpose; (b) "eligible assessee" means,— (i) any person in whose case

M/S UNITED SPIRITS LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

In the result, ground 7 is allowed for statistical purposes

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

reassessed at each reporting date. (iii) The financial closu.re of the proposed transaction as contemplated by the terms of the SPA (as may be amended and modified from time to time). is subject to satisfaction of certain condition precedent. (iv) The equity shareholders of the Company have approved the proposed sale of WMG by USGBL.The Company has filed an application

SIGMA ALDRICH CHEMICALS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, grounds 22 to 22

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.418/Bang/2015 : Asst.Year 2010-2011 It(Tp)A No.596/Bang/2016 : Asst.Year 2011-2012 M/S.Sigma Aldrich Chemicals The Deputy Commissioner Of Private Limited, No.12, Income-Tax, Circle 6(1)(1) V. Bangalore. Bommasandra-Jagani Link Road, Bommasandra Industrial Area Bangalore – 560 100. Pan : Aahcs1882L. (Appellant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 11.07.2022 Date Of Hearing : 07.07.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Final Assessment Order Dated 19.01.2015 & 28.01.2016 For Assessment Years 2010-2011 & 2011- 2012, Respectively. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

reassessment or recomputation or fresh assessment, as the case may be, expires.” 6. From the perusal of the above section 92CA(3A) of the I.T.Act, it can be seen that the TPO can pass an order at any time before 60 days prior to the due date u/s 153 of the 4 IT(TP)A No.418/B/2015 & 596/B/2016. M/s.Sigma Aldrich Chemicals

SIGMA ALDRICH CHEMICALS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, grounds 22 to 22

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.418/Bang/2015 : Asst.Year 2010-2011 It(Tp)A No.596/Bang/2016 : Asst.Year 2011-2012 M/S.Sigma Aldrich Chemicals The Deputy Commissioner Of Private Limited, No.12, Income-Tax, Circle 6(1)(1) V. Bangalore. Bommasandra-Jagani Link Road, Bommasandra Industrial Area Bangalore – 560 100. Pan : Aahcs1882L. (Appellant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 11.07.2022 Date Of Hearing : 07.07.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Final Assessment Order Dated 19.01.2015 & 28.01.2016 For Assessment Years 2010-2011 & 2011- 2012, Respectively. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

reassessment or recomputation or fresh assessment, as the case may be, expires.” 6. From the perusal of the above section 92CA(3A) of the I.T.Act, it can be seen that the TPO can pass an order at any time before 60 days prior to the due date u/s 153 of the 4 IT(TP)A No.418/B/2015 & 596/B/2016. M/s.Sigma Aldrich Chemicals

M/S UNISYS INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, grounds 10 and 11 are allowed for statistical purposes

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

reassessment or recomputation or fresh assessment, as the case may be, expires.” 8.1 From the perusal of the above section 92CA(3A) of the I.T.Act, it can be seen that the TPO can pass an order at any time before 60 days prior to the due date u/s 153 of the I.T.Act for passing the assessment order. Section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. M/S. UNISYS INDIA PVT LTD, BANGALORE

In the result, grounds 10 and 11 are allowed for statistical purposes

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

reassessment or recomputation or fresh assessment, as the case may be, expires.” 8.1 From the perusal of the above section 92CA(3A) of the I.T.Act, it can be seen that the TPO can pass an order at any time before 60 days prior to the due date u/s 153 of the I.T.Act for passing the assessment order. Section

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

reassessment under the Income-tax Act, and the time limit for completion of such action under section 153 or section 1538 thereof,\n(i) expires on the 31st day of March, 2021 due to its extension by the said notification, such time limit shall stand extended to the 30th day of April, 2021;\nPage