ENSURE BUILDERS AND DEVELOPERS ,BENGALURU vs. INCOME TAX OFFICER, WARD-1(2)(1), BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

144B without granting the partners of the assessee sufficient time to produce the documents and without considering the explanation given by the partners. 2.4 Thereafter, upon passing the assessment order, the assessees challenged the same before the NFAC and the pleaded that no opportunity was given by the Assessing Officer to produce documents and without any application of mind

CHANNAMMA RACHAPPA SARADAGI,BAGALKOT vs. INCOME TAX OFFICER, WARD-6(3)(1), BANGALORE

Appeal of the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2022-23 Mrs. Channamma Rachappa Saradagi, Vs. The Income Tax Officer, Prop. M/S. Srinidhi Transports, Ward 6(3)(1), Sangondeshwar Nagar, Kamatagi, Bangalore. Amingad, Bagalkot – 587 120. Pan: Aweps 8300D Appellant Respondent Appellant By : Shri Siddesh N Gaddi, Ca Respondent By : Shri K. Saravanan, Addl.Cit (Dr)(Itat), Bengaluru. Date Of Hearing : 28.01.2026 Date Of Pronouncement : 23.02.2026 O R D E R Per Prashant Maharishi1. Captioned Appeal For Ay 2022-23 Is Filed By Mrs. Channamma Rachappa Saradagi Against The Appellate Order Passed By The National Faceless Appeal Centre, Delhi (Nfac) [Ld. Cit(A)] Dated 29 August 2025 Wherein The Appeal Filed By The Assessee Against The Assessment Order Dated 22Nd Of March 2024 Passed Under Section 143 (3) Read With Section 144B Of The Income Tax Act, 1961 [The Act] Passed By The Learned Assessing Officer Was Dismissed. Therefore The Assessee Is In Appeal Before Us. Page 2 Of 11

144B of the Income Tax Act, 1961 [the Act] passed by the learned assessing officer was dismissed. Therefore the assessee is in appeal before us. Page 2 of 11 2. The grievance of the assessee is with respect to the (i) confirmation of addition of Rs.145,35,354/– of the addition made by the learned assessing officer under section

WEG INDUSTRIES (INDIA) PRIVATE LIMITED,BENGALURU vs. ASSESSING OFFICER, BMTC BUILDING

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

144B of the Act, is barred by limitation under section 153 of the Act, and is thus void-ab-initio, illegal and bad in law and liable to be quashed. MANUFACTURING SEGMENT 3. On the facts and circumstances of the case and in law, the Ld. Transfer Pricing Officer ('TPO')/ Ld. AO/ Hon'ble DRP erred in making

GOPAL S. PANDITH vs. DCIT,

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

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

144B of the Act and, hence, without jurisdiction. The Tribunal, in our opinion, was, therefore, justified in its conclusion that the assessment was liable to be annulled. It was right in holding that the assessment order passed by the Income- tax Officer the instant case without reference to the Inspecting Assistant Commissioner had rightly been annulled by the Commissioner

MINISTRY OF COMMUNICATIONS EMPLOYEES CO-OPERATIVE HOUSING SOCIETY LIMITED ,BANGALORE vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

section 144B of the Act dated 21.09.2022 was set aside to make a fresh assessment. 2. The assessee in the memo of appeal raised multiple grounds numbered 6 to 17, which we, for the sake of brevity and convenience are not inclined to reproduce here. Page 2 of 11 3. The brief facts of the case on hand

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

144B of the Act by the AO dated 21.07.2022 with the following grounds of appeal:- “1. That the order of the Learned Deputy Commissioner of Income-tax, Circle - 3(1)(1) ("Assessing Officer" or "Learned AO"), which is in conformity with the directions of the Dispute Resolution Panel - II, Bangalore ("DRP", "Learned Panel") and the order of the Learned Deputy

NVIDIA GRAPHICS PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BANGALORE

In the result, appeal filed by the assessee s party allowed

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2014-15 M/S. Nvidia Graphics Pvt. Ltd., Vs. Acit, Mahadevpura Village, Central Circle – 2(4), K. R. Puram Hobli, Marathalli Bangalore. Bagmane Goldstone Building, North Tower, Mahadevpura S.O, Bangalore – 560 048. Pan : Aabcn 9200 H Appellant Respondent Assessee By : Shri. Nageshwar Rao, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 17.10.2024 Date Of Pronouncement : 23.10.2024

section 147 r.w.s. 144B of the Act, vide Order dated 30.03.2022, determining the income of the assessee at Rs.1,68

BIOCON BIOLOGICS LIMITED (FORMERLY KNOWN AS BIOCON BIOLOGICS INDIA LIMITED) (SUCCESSOR TO BIOCON RESEARCH LIMITED),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.299/Bang/2022 : Asst.Year 2017-2018 M/S.Biocon Biologics Limited The Deputy Commissioner Of (Formerly Known As Biocon Income-Tax, Circle 1(1)(1) V. Biologics India Limited) Bengaluru. Ground Floor, Tower 3, Semicon Park, Hosur Road, Electronics City S.O. Bangalore South – 560 100. Pan : Aagcb7796M. (Appellant) (Respondent) Appellant By : Sri.Padam Chand Khincha, Ca Respondent By : Sri.Manjunath Karkihalli, Cit-Dr Date Of Pronouncement : 13.09.2022 Date Of Hearing : 06.09.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 26.02.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2017-2018. 2. The Brief Facts Of The Case Are As Follows: The Assessee, Namely, Biocon Biologics Limited [Successor. To Biocon Research Limited With Appointed Date 01.04.2019] Is Engaged In The Carrying Out Research & Development ("R & D") Of Drugs & Drug Delivery Systems. For The Relevant Assessment Year ("Ay") 2017-18, The Return Of Income Was Filed On 30.11.2017, Declaring `Nil’ Income Under The Normal Provisions Of The I.T.Act & Book Losses As 2 It(Tp)A No.299/Bang/2022. M/S.Biocon Biologics Limited Per The Provisions Of Section 115Jb Of The I.T.Act. After Considering The Taxes Deducted At Source, The Assessee Had Claimed Refund Of Inr 4,68,29,020 In The Return Of Income.

68,29,020 in the return of income. 3. The return of income was selected for scrutiny and notice u/s 143(2) of the I.T.Act was issued. During the course of assessment proceedings, reference was made to the Transfer Pricing Officer (TPO) for determination of Arm's Length Price ("ALP") of international transactions with its AE’s. The TPO passed

M/S. EUROFINS PEENYA RESOURCES PRIVATE LIMITED(FORMERLY KNOW AS EUROFINS ADVINUS LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

144B read with section 147 is invalid, bad in law and liable to be quashed. ITA Nos.1113 & 1114/Bang/2023 Page 4 of 18 3. Grounds relating to principles of natural justice 3.1. The CIT(A), NFAC has erred in not providing any cogent reasons in its order under section 250 of the Act, for treating the payments to foreign

EUROFINS PEENYA RESOURCES PRIVATE LIMITED (FORMERLY KNOWN AS EUROFINS ADVINUS LIMITED) ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1) , BANGALORE

In the result, the appeal for AY 2013-14 is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

144B read with section 147 is invalid, bad in law and liable to be quashed. ITA Nos.1113 & 1114/Bang/2023 Page 4 of 18 3. Grounds relating to principles of natural justice 3.1. The CIT(A), NFAC has erred in not providing any cogent reasons in its order under section 250 of the Act, for treating the payments to foreign

MR. NARAYAN DATAR SINGH,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(3)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Mr. Narayan Datar Singh Acit, Circle - 4(3)(1) Prop. Udawat Engineering Works Bmtc Building No. 78, 4Th Phase Koramangala Vs. Bommasandra Indl. Area Bengaluru 560095 Bengaluru 560099 Pan – Ainps9977R (Appellant) (Respondent) Assessee By: Shri N Rama Raju, Ca Revenue By: Shri Subramanian S., Jcit Date Of Hearing: 29.05.2024 Date Of Pronouncement: 11.06.2024

Section 147 r.w.s. 144B of the Act on 5 Mr. Narayan Datar Singh 24.03.2022 in respect of the same assessee, for the same assessment year, in which the claim of the assessee towards interest payment made to the creditors were allowed with the following observations: - “The assessee has furnished required documents, i.e., copy of ledger accounts, bank statement

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

68 as per the\nprovisions of Section 270AA of the Income tax Act, 1961 wherein\nthe due taxes had already been remitted to the revenue authorities.\nThe Appellant would like to draw the attention of Honourable\nmembers of ITAT that on a similar matter, the High Court of\nRajasthan in the case of GR Infra Projects Ltd. Vs ACIT

AHAMED ULLA KHAN ,BANGALORE vs. INCOME TAX OFFICER, WARD-2(1)(1), BENGALURU

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year :2015-16

144b(8) of the Act to the jurisdictional AO for completion of pending assessment consequent to the receipt of information from National E-Assessment Centre. Notice under section 142(1) of the Act was issued to the assessee on 07.02.2023 and it was posted for hearing on 20.02.2023. Notice under sections

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

144B of the Act incorporating the aggregate Transfer Pricing Addition of INR.3,41,80,42,376/-. 5. The Assessee filed objections before DRP. Vide letter, 14/08/2024, the Assessee placed on record the Advance Pricing Agreement (APA). Since, the Transfer Pricing Addition in relation to IT Segment, ITeS Segment and interest on receivables were coved by the APA, no directions were

CARL ZEISS INDIA (BANGALORE) PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 192/Bang/2022 Assessment Year : 2017-18 M/S. Carl Zeiss India (Bangalore) Pvt. Ltd., The Deputy Plot No. 3, Jigani Link Road, Commissioner Of Bommasandra Industrial Income Tax, Area, Circle 2 (1)(1), Bengaluru – 560 099. Vs. Bengaluru. Pan: Aadcc6152H Appellant Respondent : Shri Nageshwar Rao, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 12-04-2023 Date Of Pronouncement : 16-06-2023 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Assessment Order Dated 25.01.2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, Carl Zeiss India (Bangalore) Private Limited (Hereinafter Referred To As "Carl Zeiss India" Or "The Appellant"), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income- Tax Officer, National Faceless Center, Delhi (Hereinafter Referred To As "Ld. Assessing Officer" Or The "Ld. Ao"), Dated 25 January 2022 For The Assessment Year ("Ay")

144B of the Income-tax Act, 1961 ("the Act") in pursuance of the directions issued by Dispute Resolution Panel (hereinafter referred to as the "Hon'ble DRP"), Bengaluru dated 29 December 2021 under section 144C(5) of the Act inter-alia on the following grounds which are without prejudice to each other: That on the facts and circumstances

SAP INDIA PRIVATE LIMITED,BANGALORE vs. JURISDICTIONAL ASSESSING OFFICER - DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), BANGALORE

The appeal of the assessee is allowed to the extent indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

144B of the income tax act, 1961 (the Act) passed by the assessment unit, income tax department on 18 June 2024 pursuant to the order dated 28 July 2023 passed by the Deputy Commissioner of income tax (transfer pricing) – 2 (2) (1) (the learned TPO) and the direction issued by The Dispute Resolution Panel – 2, Bangalore (the DRP) under section

IBM INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

144B of the Income-tax Act. 1961 ('the Act'), by the National e-Assessment Centre ('the NeAC'), be struck down as invalid, as the order is bad in law and on facts. 1.2. The Hon'ble Dispute Resolution Panel ('ORP') has erred in completing the proceedings in undue haste and in violation of the principles of natural justice

KUMARSWAMY GANGASHARAISH KALLUR ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2014-15

144B of the Act, dated 30.03.2020 is erroneous in so far as it is prejudicial to the interest of the Revenue in terms of section 263 of the Act, and reassessment Order was set aside, the AO is directed under section 263 of the Act to make fresh assessment in accordance with law and as per CBDT instructions