DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

HEWLETT-PACKARD GLOBALSOFT PRIVATE LIMTIED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

section 10A and 10B of the Act 10,90,60,594 As per ROI 99,59,24,204 Less: As per FAO 88,68,63,610 Disallowance on account of difference of service income in the 7

DCIT, BANGALORE vs. M/S HEWLETT PACKARD GLOBALSOFT PVT. LTD.,, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

section 10A and 10B of the Act 10,90,60,594 As per ROI 99,59,24,204 Less: As per FAO 88,68,63,610 Disallowance on account of difference of service income in the 7

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

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

68,25,501 under section 234B of the Act. 11.2. The learned ACIT has erred in law and on facts in not granting credit for foreign taxes paid by the Appellant. 12. Relief 12.1. The Appellant prays that directions be given to grant all such relief arising from the preceding grounds as also all reliefs consequential thereto

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

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

7. Companies having different financial year ending (i.e.. not March 31, 2010) or data of the company which does not fall within 12 month period i.e., 01.04.2009 to 31.03.2010 - excluded 8. Companies that are functionally different - excluded Companies having peculiar economic circumstances - excluded 9. 15. After applying the above filters, the Ld.TPO retained 3 comparables that was selected

M/S DELL INTERNATIONAL SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal is allowed

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

7 of 48 Here in this case also the segmental details of operating income of IT services and sale of software products have not been provided so as to see whether the profit ratio of this company can be taken into consideration for comparing the case that of assessee. In absence of any kind of details provided

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

7 of 37 12.2 The learned AO has, therefore, erred in computing income from 10A eligible units at a loss of INR 13,89,18,621 as against loss of INR 14,19,45,354. (III) Transfer pricing grounds 12. Corporate guarantee commission imputed at INR 2,83,32,477 13.1 The learned TPO and the learned AO have erred

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

7 of 37 12.2 The learned AO has, therefore, erred in computing income from 10A eligible units at a loss of INR 13,89,18,621 as against loss of INR 14,19,45,354. (III) Transfer pricing grounds 12. Corporate guarantee commission imputed at INR 2,83,32,477 13.1 The learned TPO and the learned AO have erred

DCIT, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

7 of 37 12.2 The learned AO has, therefore, erred in computing income from 10A eligible units at a loss of INR 13,89,18,621 as against loss of INR 14,19,45,354. (III) Transfer pricing grounds 12. Corporate guarantee commission imputed at INR 2,83,32,477 13.1 The learned TPO and the learned AO have erred

ITO, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

7 of 37 12.2 The learned AO has, therefore, erred in computing income from 10A eligible units at a loss of INR 13,89,18,621 as against loss of INR 14,19,45,354. (III) Transfer pricing grounds 12. Corporate guarantee commission imputed at INR 2,83,32,477 13.1 The learned TPO and the learned AO have erred

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. M/S TATA ELXSI. LTD, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section 155(11A) of the Act, held that the same should be considered as export turnover of the current year, placing reliance on the decision of the Hon’ble Karnataka High Court in the case of Wipro

M/S TATA ELXSI LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section 155(11A) of the Act, held that the same should be considered as export turnover of the current year, placing reliance on the decision of the Hon’ble Karnataka High Court in the case of Wipro

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. M/S TATA ELXSI. LTD., BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section 155(11A) of the Act, held that the same should be considered as export turnover of the current year, placing reliance on the decision of the Hon’ble Karnataka High Court in the case of Wipro

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INFOSYS BPO LTD, BANGALORE

In the result appeal filed by assessee stands partly allowed

Bench: Shri J. Sudhakar Reddy & Smt.Beena Pillai

7 Ld.AO observed that assessee incurred expenditure of Rs.15,67,08,619/- towards telecommunication charges attributable to delivery of software outside India, which was excluded from both export turnover and total turnover for computation of deduction under section 10A of relevant undertaking. Ld.AO observed that sum of Rs.11,69,38,859/- was treated as deferred revenue not considered

AMERICAN POWER CONVERSION (INDIA) PRIVATE LIMITED,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, appeal of the assessee stands partly allowed as indicated herein above

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 1111/Bang/2012 Assessment Year : 2008-09

68,94,858 The learned AO has erred in computing interest under section 234B of the Act consequent to the above adjustments. 13. Calculation of Interest on resulting adjustment under section 234D of the Act: Rs. 1,98,82,191 The learned AO has erred in computing interest under section 234D of the Act consequent