M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial pronouncements as would justify

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial pronouncements as would justify

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial pronouncements as would justify

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial pronouncements as would justify

SHRI. NAGARAJ VINAYAK JOSHI,KARAWAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahu

additional income over and above the regular income for the relevant Assessment Year viz., Assessment Year 2018-19. The assessment was concluded by assessing Rs.20 lakhs as part of the income of the assessee from business of construction of residential houses. On identical facts, the Bangalore Bench of the Tribunal in the case of Kusuma Cashes Vs. PCIT

SHRI. NAGARAJ VINAYAK JOSHI,KARAWAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahu

additional income over and above the regular income for the relevant Assessment Year viz., Assessment Year 2018-19. The assessment was concluded by assessing Rs.20 lakhs as part of the income of the assessee from business of construction of residential houses. On identical facts, the Bangalore Bench of the Tribunal in the case of Kusuma Cashes Vs. PCIT

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\nanalysis undertaken by the Appellant in accordance with the provision\nof the Act read with Income-tax Rules, 1962 ("the Rules") and holding\nthat the Appellant's impugned international transactions pertaining to\ntrading segment, payment of intra group services and trade receivables\nare not at arm's length.\nAdjustment on account of trading segment\n4.\nThe

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

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

income on 23/02/2022 which was revised on 09/05/2024. Thereafter, the case of the Assessee was selected for scrutiny. During the assessment proceedings reference was made to the Transfer Pricing Officer (for short ‘the TPO’) for determination of Arm’s Length Price (ALP) of the international transactions entered into by the Assessee with its Associated Enterprises (AEs) during the relevant previous

CONCUR TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1), BANGALORE

Appeal of the assessee is partly allowed as indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

addition of INR 126,766,855 to the total income of the Appellant on account of adjustment in the arm's length price ("ALP") for international transactions entered by the Appellant with its associated enterprises ("AEs") as follows: 2.1. INR 18,049,387 in respect of provision of information technology ("IT") support services/ software development ("SWD") services

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 dated 29.01.2021 under section 92CA of the Act and concluded that the international transactions of the assessee were at arm’s length and no adjustment was warranted. As per Assessment Order: 3.3 The learned Assessing Officer passed the assessment order on 22.04.2021 and made the following disallowances / additions to the returned income

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 dated 29.01.2021 under section 92CA of the Act and concluded that the international transactions of the assessee were at arm’s length and no adjustment was warranted. As per Assessment Order: 3.3 The learned Assessing Officer passed the assessment order on 22.04.2021 and made the following disallowances / additions to the returned income

SRI. GIREESHSHASTRI SHANKARSHASTRI JEERE ,GAJENDRAGAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2018-19 Shri Gireeshshastri Shankarshastri Jeere, The Principal Commissioner Of Prop : Fakeeresh Fuels, Income Tax (Central), Kustagi Road, Main Road, Vs. Bengaluru. Gajendragad – 582 114. Pan : Agupj 2460 M Appellant Respondent Assessee By : Shri. R. Chandrashekar, Advocate Revenue By : Shri. D. K. Mishra, Cit (Dr)(Itat), Bengaluru. Date Of Hearing : 15.06.2023 Date Of Pronouncement : 16.06.2023

additional income over and above the regular income for the relevant Assessment Year viz., Assessment Year 2018-19. The assessment was concluded by assessing Rs.20 lakhs as part of the income of the assessee from business of construction of residential houses. On identical facts, the Bangalore Bench of the Tribunal in the case of Kusuma Cashes Vs. PCIT

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

income at Rs.13,85,41,440. This assessment order is challenged before us. 11. The learned authorized representative submitted facts of the case, discussed the international transaction and benchmarking of the IT(TP)A No.1681/Bang/2024 Page 7 of 17 assessee as well as the benchmarking methodology adopted by the learned transfer pricing officer which has resulted into the addition

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 including an addition of ₹ 924,872,078 on account of excessive expenditure incurred towards Advertisement, Marketing and Promotion [AMP] amounting to ₹ 922,592,886 and an additional adjustment of ₹ 2,279,192/– on account of interest on delayed receivables and further disallowance of expenditure amounting to ₹ 24,66,60,121/– was made determining the total income

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

Transfer Pricing\nAddition to INR.104,00,59,562/- and the Assessing Officer passed\nthe Final Assessment Orders, dated 17/10/2019, assessing income\nof the Assessee at INR.309,31,53,514/- in the following manner\nafter making following additions

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

price being inflated cannot be ruled out and there is no material to dislodge such finding. The issue is not whether the purchase price reflected in the books of account matches the purchase price stated to have been paid to other persons. The issue is whether the purchase price paid by the assessee is reflected as receipts by the recipients

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

Income-tax Act,1961 ['the Act' for short] dated 21.10.2019. 2. Facts of the case are that the learned Transfer Pricing Officer (“TPO”) has passed the transfer pricing (“TP) order dated 17.10.2018 under section 92CA of the Act and has made the following adjustments: IT(TP)A No.2532/Bang/2019 United Brewries Ltd., Bangalore Page 2 of 70 S No Particulars Amount

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 adjustment cannot be made on a hypothetical and notional basis unless there is material on record that there has been under charging of real income. d. Erred in imputing interest on delayed receivables without giving cognizance to the fact that the primary transaction of manufacturing has been tested by the Learned TPO and the receivables are arising

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, appeals of the assessee in ITA Nos

Income Tax (Appeals) as well as by\nthe Tribunal. However, it is pertinent to note that the books of accounts\nhave not been touted by any of the authorities under the Act. A Bench of\nthis Court vide judgment dated 24.03.2015 passed in ITA No.22/2015, has held\nthat admittedly the normal practice in the line of business of the assessee