PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

reassessment proceedings under section 147 of the Act are invalid and bad in law. 3. Assessment Order passed by the Learned AO under section 144 rws 147 rws 144C(13) of the Act is barred by limitation under section 153 of the Act 3.1. On the facts and in the circumstances of the case and in law, the Assessment Order

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

methods of performance are forbidden. Once the statute has prescribed a limitation period for passing the final order, it is expected that the internal procedure of the Department should mould itself to give meaning to and act in aid of the provision. Any procedural defect (there is none in this case) in the internal mechanism of the working

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

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

reassessment proceeding had to be completed. Accordingly, the AO IT(IT)A Nos.191 to 194/Bang/2024 Page 4 of 43 passed the draft assessment order making additions towards royalty income as under:- Asst. Year Amount

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

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

reassessment proceeding had to be completed. Accordingly, the AO IT(IT)A Nos.191 to 194/Bang/2024 Page 4 of 43 passed the draft assessment order making additions towards royalty income as under:- Asst. Year Amount

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

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

TP)A 1513 to\n1516/Bang/2013 the issue was decided in favour of GIPL by the Tribunal by\nholding that the impugned payment made by it to GIL cannot be\ncharacterised as royalty under Act or DTAA. The relevant findings of the\nTribunal in the case of payer, i.e. GIPL reads as follows: -\n“13. We have heard rival submissions

GOOGLE LLC (FORMERLY KNOWN AS GOOGLE INC.),CALIFORNIA vs. JOINT COMMISSIONER OF INCOME TAX (OSD) INTERNATIONAL TAXATION, CIRCLE-1(1), BANGALORE

In the result, the appeals filed by the assessee are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.It(It)A No. 167/Bang/2021 - Ay : 2010-11) It(It)A No. 688/Bang/2022 - Ay : 2012-13)

reassessment proceedings the matter was referred to the Transfer Pricing Officer (TPO) to determine the arm's length price (ALP) of the payments received by the assessee. The TPO held that the international transactions with the Associated Enterprises (AE) were at ALP and hence no adjustment is required. However, the AO observed that the assessee company received payments from GIPL