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

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

business income and taxed it under the normal provision. The relevant finding of the Bangalore Bench of the Tribunal in the case of Kusuma Cashes Vs. PCIT (supra) reads as follows: “9. We have heard the rival submissions and perused the material on record. Before proceeding further, it is apposite to take note of the relevant extract of section

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

business income and taxed it under the normal provision. The relevant finding of the Bangalore Bench of the Tribunal in the case of Kusuma Cashes Vs. PCIT (supra) reads as follows: “9. We have heard the rival submissions and perused the material on record. Before proceeding further, it is apposite to take note of the relevant extract of section

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

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

Pricing Agreement, the assessee has filed modified ITR u/s 139 r.w.s. 92CD of the Income- tax Act,1961 ['the Act' for short] on 19.10.2020 declaring income of Rs.23,19,09,830/-. The other statutory notices were issued to the assessee. 2.1 The assessee company is engaged in providing software development services including testing, infrastructure support and other related services

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

income. Hence, the ground raised by the assessee is hereby allowed. 19. The next issue raised by the assessee through Ground Nos. 3.1 to 3.4 is pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

income. Hence, the ground raised by the assessee is hereby allowed. 19. The next issue raised by the assessee through Ground Nos. 3.1 to 3.4 is pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

income. Hence, the ground raised by the assessee is hereby allowed. 19. The next issue raised by the assessee through Ground Nos. 3.1 to 3.4 is pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered

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

Business Solutions India Pvt. Ltd., Bengaluru Page 32 of 50 5 Stand over to 22nd August 2023.” 13. Pursuant to our directions of 1st August 2023, two affidavits were filed, one by Mr. Satish Sharma, the Chief Commissioner of Income Tax (International Taxation and Transfer Pricing

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

transfer Finacle\nUniversal Banking Solution Business division and Edge-services Business\ndivision for a consideration of 3222 crores and 177 crores respectively\nwhich aggregates to Rs. 3399 crores. As per the assessee, the\nconsideration for purchase of the business division was made for\nbundled of assets comprising in those division without any breakup or\ndivision of the price over assets

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

business of manufacture and sale of beer under different brands like ‘Kingfisher’ and ‘UB’. The assessee for the AY 2016-17 filed its return of income on 29.11.2016 declaring total income Rs.461,47,05,660/-. The case of the Appellant was thereafter selected for scrutiny assessment. As per Transfer Pricing

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

business of manufacture and sale of beer under different brands like ‘Kingfisher’ and ‘UB’. The assessee for the AY 2016-17 filed its return of income on 29.11.2016 declaring total income Rs.461,47,05,660/-. The case of the Appellant was thereafter selected for scrutiny assessment. As per Transfer Pricing

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU vs. NALAPAD HOTELS AND CONVENTION CENTRE, BENGALURU

In the result, both appeals of the revenue are allowed for\nstatistical purposes

transfer / exchange of stock in trade has taken place between two\nentities/ persons the transaction is a business transaction and any income derived /\naccrued will be a business income. In view of this the difference in value of the\nbuilding to the value of the land is to be taxed as business income.\n\n2.1 Thereafter, the AO took

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

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

Bench: Shri George George K. & Shri Chandra Poojari

transfer, then, for the purposes of the deduction under this section, the profits and gains of the industrial undertaking or the business of the hotel shall be computed as if the transfer, in either case, had been made at the market value of such goods as on that date : Provided that where, in the opinion of the Assessing Officer

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

business and team composition, while supporting them through variety of team project models ranging from contract staffing to project based staffing. 4. Assessee company filed its return of income on 5.2.2021 at a total income of Rs. 5,00,90,640/-. Return of income was selected for scrutiny where one of the reason was large value of international transaction

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

price with “market value” when there is transfer of goods or services (a) from “eligible business” to “any other business” carried on by the assessee or (b) from “any other business” to “eligible business” carried on by the assessee. Section 10A/10AA/10B, 80IA etc., grants income

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

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 method. In general, closely comparable products/services are required if the comparable uncontrolled price ('CUP') method is used for arms' length pricing; the resale price, cost-plus methods generally require a lesser degree of products or services comparability and may be appropriate if functional comparables are available. The TNMM requires only broad functional and product/services comparability. In many instances

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

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

Business Park, 150, Outer Ring Road, Kadabeesanahalli, Bellandur, Karnataka – 560 103 [PAN: AACCG2435N] …………. Appellant Vs Deputy Commissioner of Income Tax, Circle 3(1)(1) BMTC Building, Koramangala, Bangalore, Karnataka – 560095. …………. Respondent Appearance For the Appellant/Assessee : Shri Madhur Agarwal For the Respondent/Department : Dr. Divya K. J. Date Conclusion of hearing : 27.11.2025 Pronouncement of order