DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

In the result, the appeal filed by the Revenue is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal to fifty per cent of the amount of tax payable on under-reported income. (8)Notwithstanding

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal to fifty per cent of the amount of tax payable on under-reported income. (8)Notwithstanding

UNITED BREWERIES LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-7(1)(1), BENGALURU

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

92D and 92E, “specified domestic transaction” in case of an assessee means any of the following transactions, not being an international transaction, namely:— (i) any expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of sub- section (2) of section 40A. (ii) any transaction referred

M/S SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

92D of the Act in good faith and with due diligence; (corresponding to revised ground no. 2.1 & original ground no. 2.1) 2.2 Disregarding the application of multiple-year data while computing the profit level indicators ("PLI") of the comparable companies; (corresponding to revised ground no. 2.2 & original ground no. 2.2) 2.3 Using data, which was not contemporaneous and which

D.C.I.T., BANGALORE vs. M/S SAP LABS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

92D of the Act in good faith and with due diligence; (corresponding to revised ground no. 2.1 & original ground no. 2.1) 2.2 Disregarding the application of multiple-year data while computing the profit level indicators ("PLI") of the comparable companies; (corresponding to revised ground no. 2.2 & original ground no. 2.2) 2.3 Using data, which was not contemporaneous and which

M/S.NIKE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, 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 NIKE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), 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

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