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

154 of the Act before the AO. 3.7 The AO vide order dated 14.02.2023 has rectified the following mistakes in his order: Particulars Amount as per AO Amount after order rectification Payments to UBHL 15,20,63,311 4,15,04,955 Disallowance under section 2,54,85,000 25,48,500 14A of the Act Disallowance of sponsorship

VINOD PRASAD INJETI ,BANGALORE vs. INCOME TAX OFFICER, WARD-2(3)(3), BANGALORE

In the result, we reverse the orders of the ld

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2014-15

price of Rs.1 Crore, long term capital loss was determined at a loss of Rs.85,79,967. 6. Subsequently a rectification order was passed on 22.2.2017 with assessed income of Rs. 2,24,418. Subsequent to that, another Page 5 of 10 rectification was carried out by order u/s. 154 of the Act on 29.12.2017. In that rectification order

M/S. AARIS GROUP INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(1), BANGALORE

In the result the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 177/Bang/2022 (Assessment Year: 2017-18)

rectification 22.01.2021 Order u/s 154 Adjustment in respect of Software Development 4,47,949,052 20,17,03,783 segment Adjustment in respect of 2,06,66,030 2,06,66,030 ITeS segment Total TP adjustment 468,615,082 22,23,69,813 3. On receipt of the transfer pricing

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

transfer pricing adjustment were set out in the following manner:- (a) Adjustment for difference in price in Software Development Segment (b) Adjustment for interest on advances given to overseas subsidiaries (c) Adjustment made for Corporate guarantee commission (d) Adjustment for Specified Domestic Transaction(SDT) (e) Adjustment for interest on delayed trade receivables IT(TP)A No.370/Bang/2021 Page

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")

Transfer Pricing) u/s 92CA(1) of the Act for the determination of Arms Length Price (ALP) for AY 2017-18. 4.2 The Ld.TPO on receipt of the reference called upon assessee to file requisite details in form 3CEB. The Ld.TPO noted that, the assessee provides after sales support services for Carl Zeiss products in India. The company caters to both

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

Transfer Pricing Officer or any other authority;\n(e) records relating to the draft order;\n(f) evidence collected by, or caused to be collected by, it; and\n(g) result of any enquiry made by, or caused to be made by, it.\n(7) The Dispute Resolution Panel may, before issuing any directions referred to in sub-section

MICROSOFT RESEARCH LAB INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(1)(1), BENGALURU

In the result, the appeal is set aside for doing it denovo

Bench: Ms. Padmavathy S. & Shri Rahul Chaudhary

transfer pricing adjustments in toto. Considering these facts no discussion of the grounds of appeal is made here. The TPO’s order is to be considered as the order appealed against. The rectification order passed on 1.6.2021 u/s 154

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment

M/S. MAKINO INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2), BANGALORE

In the result, the appeal is allowed for statistical purposes

Bench: Shri George George K. & Ms. Padmavathy S

Transfer Pricing adjustment should be restricted to the value of international transactions with associated enterprise under the Slim sub-segment only because admittedly thee are international transactions with the AEs under Non-Slim segment also. The assessee has not given any justification or documentation as to why the adjustment should be restricted to the transactions in the Slim Sub-segment

GREEN ORCHAND FARM HOUSES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

rectification u/s 154 of the Act dated 15.10.2019 as follows: Green Orchard Farm Houses, Bangalore Page 12 of 25 Green Orchard Farm Houses, Bangalore Page 13 of 25 5.2 Later, there was an enquiry conducted in the case of Manipal Academy of Higher Education and notice u/s 133(6) of the Act has been issued and it was found that

ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing analysis, the purpose is not to compare profit of the tested party with that of the comparables but the purpose is to compare the prices charged by the tested, party with the prices charged by the comparables although when TNMM is adopted as MA.M, the process of such price comparison is by comparing profits of tested party with

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 partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

154 of the Act wherein he recomputed the amount of notional interest on delayed receivable at Rs. 3,68,918/- only. Hence, the TPO in IT(TP)A No.2346/Bang/2024 Page 18 of 44 rectification order reduced the interest adjustment from Rs. 58,83,783/- to Rs. 3,68,918/- only. 30.1 The learned DRP in principle confirmed the view

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. DELL INTERNATIONAL SERVICES INDIA PVT LTD, BENGALURU

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

rectification order passed\nunder section 154 of the Act. As per the AO, though the enhanced\ndeduction was allowed by the ITAT vide order dated 24-06-2020 for the\nAY 2007-08 in ITA No. 879/Bang/2020 in own case of the assessee, but\nthe same was challenged before the higher forum.\n3. On appeal before

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

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

transfer pricing, a vital factor in determining the arm's length pricing of assessee's international transactions. We have also noted that the assessee had specifically taken up the issue of appreciation of this unique 50:50 business model before the DRP in the assessment years 2007-08 and 2008-09. As regards the assessment year