DECATHLON SPORTS INDIA PRIVATE LIMITED,BANGALORE , KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 2(2)(1), BENGALURU, KARNATAKA

In the result appeal of the assessee is partly allowed as indicated\nabove

transfer pricing mechanism\nin the most reliable manner.\n33. On reading of the transfer pricing study report prepared by the\nassessee

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Transfer Pricing Order: 2.2 The learned Transfer Pricing Officer (“TPO”) has passed the transfer pricing (“TP) order dated 30.10.2019 under

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Transfer Pricing Order: 2.2 The learned Transfer Pricing Officer (“TPO”) has passed the transfer pricing (“TP) order dated 30.10.2019 under

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

transfer pricing adjustment envisages the substitution of the price of such international transaction with the arm's length price. The transfer

ATMECS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(1)(1), BANGALORE

In the result, the appeal of assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

transfer pricing guidelines 2017, the ICAI transfer pricing guidance note, several judicial precedents as well the decision in assessee's own case

QUINTILES RESEARCH (INDIA) PVT. LTD.,BANGALORE vs. THE DY.CIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the\ndepartmental appeal is dismissed

Transfer Pricing Order made by the Transfer Pricing Officer\n('TPO') dated 30.01.2015 for Assessment Year 2011-12 ('A.Y\n2011

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

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

Transfer Pricing Officer, the assessee's submission in response to the same and order of the Transfer Pricing Officer for Assessment

DY.COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2),, AHMEDABAD vs. M/S.QUINTILES RESEARCH INDIA PVT.LTD.,, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the departmental appeal is dismissed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2011-12

Transfer Pricing Order made by the Transfer Pricing Officer ('TPO') dated 30.01.2015 for Assessment Year 2011-12 ('A.Y 2011-12') was barred

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, CIRC-2(1)(1), BANGALORE

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 342/Bang/2022 Assessment Year : 2017-18 M/S. Deliverhealth Solutions India Pvt. Ltd. (Earlier Known As Nuance Transcription Services India Pvt. Ltd.) The Joint First Floor, Block B, Commissioner Of Salarpuria Aura, Income Tax, Khata No. 434/170, Circle 2(1)(1), Marathahalli –Sarjapur Outer Vs. Bangalore. Ring Road, Kaverappa Layout, Kadubeesanahalli, Bangalore – 560 103. Pan: Aaacf3465F Appellant Respondent

Transfer Pricing Officer ("TPO") have erred in making a transfer pricing adjustment of INR 18,34,63,116, in respect

KENNAMETAL INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Transfer Pricing The grounds mentioned hereinafter are without prejudice to one another. 2.1 The Learned AO, Learned Transfer Pricing Officer

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

price. Thus, the statutory framework itself limits the scope of transfer pricing adjustments only to transactions entered with associated enterprises

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

Transfer Pricing Guidelines for Multinational\nEnterprises and Tax Administrations (2022)\nParagraph 2.2\n[Chapter II: Transfer Pricing Methods Part I: Selection

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

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Transfer Pricing Officer (“TPO”) has passed the transfer pricing (“TP) order dated 17.10.2018 under section 92CA of the Act and has made

EBIX TRAVELS PVT. LTD.,NEW DELHI vs. DCIT,CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result appeal of the assessee is partly allowed

transfer pricing\nstudy report by the assessee.\nvi. He submitted that only for the reason, the transfer pricing\nstudy of the assessee

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

transfer pricing provisions and various judicial precedents, we hold that the transfer pricing adjustment should be restricted only to the AE related

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

In the result appeal filed by the assessee is partly allowed

transfer pricing officer rejected the transfer pricing study\nreport challenging some of the filters and the fact that the search

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TRANSFER PRICING (TP) MATTERS Rejection of transfer pricing documentation and making adjustments 1. Erred in rejecting the contemporaneous transfer pricing

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TRANSFER PRICING (TP) MATTERS Rejection of transfer pricing documentation and making adjustments 1. Erred in rejecting the contemporaneous transfer pricing