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100 results for “transfer pricing”+ Rectification u/s 154clear

Sorted by relevance

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Key Topics

Section 143(3)85Section 15465Transfer Pricing58Section 92C55Addition to Income55Section 10A47Comparables/TP38Disallowance28Rectification u/s 15427

M/S. UNITED SPIRITS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 489/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 May 2020AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleit(Tp)A No.489/Bang/2017 (Assessment Year: 2012-13) M/S. United Spirits Limited, Ub Towers, No.24, Vittal Mallya Road, Bangalore-560 001 ….Appellant Vs. Dy. Commissioner Of Income Tax, Circle 7(1)(1), Bangalore. ……Respondent. Assessee By: Shri Perci Pardiwala, Senior Advocate & Shri Ketan Ved, C.A. Revenue By: Shri Bipin C.N, Jcit (D.R) Date Of Hearing : 06.03.2020. Date Of Pronouncement : 29.05.2020. O R D E R Per Shri B.R. Baskaran, A.M. : The Assessee Has Filed This Appeal Challenging The Assessment Order Dated 31-01-2017 Passed By The Assessing Officer For Assessment Year 2012-13 Passed U/S 143(3) R.W.S 144C(13) Of The Act.

For Appellant: Shri Perci Pardiwala, Senior Advocate and Shri Ketan Ved, C.AFor Respondent: Shri Bipin C.N, JCIT (D.R)
Section 143(3)Section 144C(10)Section 144C(13)Section 14ASection 154Section 36(1)(iii)

Showing 1–20 of 100 · Page 1 of 5

Deduction25
Section 3521
Section 1118
Section 92C

Transfer Pricing matters:- 1.Adjustment for interest free loan to AE - Rs. 45,69,73,626/- (B) Corporate Tax matters:- 2. Disallowance u/s 14A of the Act - Rs. 94,97,00,000/- 3. Disallowance u/s 36(1)(iii) - Rs.348,72,00,000/ 3 IT(TP)A No.489/Bang/2017 . 4. Disallowance of payments for Promotion and advertisement

INVTEVA PRODUCTS INDIA AUTOMOTIVE PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed in the terms indicated above

ITA 830/BANG/2017[2012-13]Status: DisposedITAT Bangalore18 Jan 2019AY 2012-13

Bench: Shri A. K. Garodia & Shri Laliet Kumar

For Appellant: Shri M. P. Lohia, C. AFor Respondent: Shri C. H. Sundar Rao, CIT (DR)
Section 143Section 143(3)Section 144Section 253(1)(d)

Transfer pricing adjustment without giving benefit of +/- 5 percent as available under proviso to section 92C(2) of the Act Erred in computing the arm's length price of the international transactions, without taking into account the benefit of +/- 5 per cent variation from the mean where it is within the range, which is permitted and opted

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

ITA 308/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Aug 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

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

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

ITA 345/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Aug 2023AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

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

M/S BRADY COMPANY INDIA PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(4), BANGALORE

In the result, ground 26 is allowed for statistical purposes

ITA 103/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.103/Bang/2019 : Asst.Year 2014-2015 It(Tp)A No.790/Bang/2019 : Asst.Year 2014-2015 M/S.Brady Company India Private The Income Tax Officer Limited, No.26, Survey No.41 Ward 1(1)(4) V. Bengaluru. Konappana Agrahara Village Begur, Hobli, Electronci City, Phase-Ii, Bengaluru – 560 100. Pan : Aaccb8163A (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 22.03.2022 Date Of Hearing : 07.03.2022 O R D E R Per George George K, Jm : These Appeals Are At The Instance Of The Assessee. The Relevant Assessment Year Is 2014-2015. 2. The Reason For Filing Two Appeals For Assessment Year 2014-2015 Is That Pursuant To The Dispute Resolution Panel’S (Drp) Directions (Directions Dated 28.09.2008), The A.O. Passed Final Assessment Order U/S 143(3) R.W.S. 144C Of The I.T.Act Dated 15.11.2018. In The Said Assessment Order, The Aggregate Transfer Pricing Adjustment Was Determined At Rs.14,43,51,081. An Appeal Has Been Filed Before The Tribunal Against The Order U/S 143(3) R.W.S. 144C Of The I.T.Act (Appeal No.It(Tp)A No.103/Bang/2019). Subsequently, On Application By The Assessee, The Drp Passed Rectification Order Dated

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 154

rectification order u/s 154 of the I.T.Act giving effect to the revised directions of the DRP. An appeal has been filed before the Tribunal against the order u/s 154 of the I.T.Act also. 3. The learned AR during the course of hearing submitted that IT(TP)A No.790/Bang/2019 (arising out of 154 order) may be dismissed as infructuous. In view

M/S BRADY COMPANY INDIA PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(4), BANGALORE

In the result, ground 26 is allowed for statistical purposes

ITA 790/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.103/Bang/2019 : Asst.Year 2014-2015 It(Tp)A No.790/Bang/2019 : Asst.Year 2014-2015 M/S.Brady Company India Private The Income Tax Officer Limited, No.26, Survey No.41 Ward 1(1)(4) V. Bengaluru. Konappana Agrahara Village Begur, Hobli, Electronci City, Phase-Ii, Bengaluru – 560 100. Pan : Aaccb8163A (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 22.03.2022 Date Of Hearing : 07.03.2022 O R D E R Per George George K, Jm : These Appeals Are At The Instance Of The Assessee. The Relevant Assessment Year Is 2014-2015. 2. The Reason For Filing Two Appeals For Assessment Year 2014-2015 Is That Pursuant To The Dispute Resolution Panel’S (Drp) Directions (Directions Dated 28.09.2008), The A.O. Passed Final Assessment Order U/S 143(3) R.W.S. 144C Of The I.T.Act Dated 15.11.2018. In The Said Assessment Order, The Aggregate Transfer Pricing Adjustment Was Determined At Rs.14,43,51,081. An Appeal Has Been Filed Before The Tribunal Against The Order U/S 143(3) R.W.S. 144C Of The I.T.Act (Appeal No.It(Tp)A No.103/Bang/2019). Subsequently, On Application By The Assessee, The Drp Passed Rectification Order Dated

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 154

rectification order u/s 154 of the I.T.Act giving effect to the revised directions of the DRP. An appeal has been filed before the Tribunal against the order u/s 154 of the I.T.Act also. 3. The learned AR during the course of hearing submitted that IT(TP)A No.790/Bang/2019 (arising out of 154 order) may be dismissed as infructuous. In view

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

In the result, we reverse the orders of the ld

ITA 1252/BANG/2024[2014-15]Status: DisposedITAT Bangalore22 Nov 2024AY 2014-15

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

For Appellant: Smt. Jyothi Anumolu, AdvocateFor Respondent: Shri Ganesh R. Gale, Standing Counsel
Section 143(3)Section 154Section 234A

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

SASKEN TECHNOLOGIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 404/BANG/2017[2012-13]Status: DisposedITAT Bangalore30 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 404/Bang/2017 Assessment Year : 2012-13 M/S. Sasken Technologies Ltd., (Formerly Known As The Deputy Sasken Communication Commissioner Of Technologies Ltd.), Income Tax, No. 139/25, Domlur Circle – 6(1)(1), Ring Road, Vs. Bangalore. Bangalore – 560 071. Pan: Aaecs6424R Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca : Shri K. Sankar Ganesh, Jcit Revenue By Dr Itat Date Of Hearing : 15-11-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Assessment Order Dated 31.01.2017 Passed By Ld.Dcit, Circle – 6(1)(1), Bangalore For A.Y. 2012-13 On Following Concise Grounds Of Appeal: “1. General:- The Learned Ao & The Drp Erred In Passing The Order / Directions In The Manner Passed By Them. The Orders Passed Being Bad In Law Is Liable To Be Quashed.

For Respondent: Shri Padam Chand Khincha
Section 133(6)Section 2(24)Section 92BSection 92C

u/s 154 on 05.02.2016. The Ld.TPO passed the order under section 154 on 22.02.2016. 2.3 The TPO made the following adjustments in the TP order read with the rectification order: Amount Particulars (Rs.) Interest on loan to subsidiaries 1,96,54,734 Corporate Guarantee 2,75,238 Royalty from AEs for using trademark 1,90,75,332 Shortfall in receipts

DCIT, BANGALORE vs. M/S ROBERT BOSCH ENGINEERING & BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal filed by assessee stands allowed as indicated above and the appeal filed by revenue stands dismissed

ITA 445/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Feb 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 608/Bang/2016 Assessment Year : 2011-12 M/S. Robert Bosch The Deputy Engineering & Business Commissioner Of Solutions Pvt. Ltd., Income Tax, #123, Industrial Layout, Large Tax Payers Unit, Hosur Road, Koramangala, Circle 1, Bangalore – 560095. Vs. Bangalore. Pan: Aaacr7108R Appellant Respondent & It(Tp)A No. 445/Bang/2016 Assessment Year : 2011-12 (By Revenue) : Shri Percy Padiwala, Sr. Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 20-12-2021 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Final Assessment Order Dated 28.01.2016 By The Ld.Dcit, Ltu, Circle -1, Bangalore U/S. 143(3) R.W.S. 144C Of The Act For Assessment Year 2011-12. In Revenue’S Appeal, The Following Grounds Are Raised. “1. The Directions Of Drp Is Opposed To Law & Facts Of The Case.

Section 10ASection 143(3)Section 144CSection 14ASection 80J

Rectification under section 154 to reject a comparable company, which is otherwise accepted by the learned Panel, on the ground that it does not clear Page 4 of 33 IT(TP)A Nos. 445 & 608/Bang/2016 the export turnover filter > 75% of total sales as applied by the learned TPO at the time of Assessment Proceedings b) Not considering corrected operating

M/S ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by assessee stands allowed as indicated above and the appeal filed by revenue stands dismissed

ITA 608/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Feb 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 608/Bang/2016 Assessment Year : 2011-12 M/S. Robert Bosch The Deputy Engineering & Business Commissioner Of Solutions Pvt. Ltd., Income Tax, #123, Industrial Layout, Large Tax Payers Unit, Hosur Road, Koramangala, Circle 1, Bangalore – 560095. Vs. Bangalore. Pan: Aaacr7108R Appellant Respondent & It(Tp)A No. 445/Bang/2016 Assessment Year : 2011-12 (By Revenue) : Shri Percy Padiwala, Sr. Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 20-12-2021 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Final Assessment Order Dated 28.01.2016 By The Ld.Dcit, Ltu, Circle -1, Bangalore U/S. 143(3) R.W.S. 144C Of The Act For Assessment Year 2011-12. In Revenue’S Appeal, The Following Grounds Are Raised. “1. The Directions Of Drp Is Opposed To Law & Facts Of The Case.

Section 10ASection 143(3)Section 144CSection 14ASection 80J

Rectification under section 154 to reject a comparable company, which is otherwise accepted by the learned Panel, on the ground that it does not clear Page 4 of 33 IT(TP)A Nos. 445 & 608/Bang/2016 the export turnover filter > 75% of total sales as applied by the learned TPO at the time of Assessment Proceedings b) Not considering corrected operating

M/S MAXIM INDIA INTERGRATED CIRCUIT DESIGN PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

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

ITA 1573/BANG/2017[2013-14]Status: DisposedITAT Bangalore02 Nov 2020AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Gollapinni Mallikarjuna, D.R
Section 143(3)Section 234CSection 40

transfer pricing exercise would therefore fail. Therefore in keeping with the OECD guidelines, endeavor should be made to bring in comparable companies for the purpose of broad comparison. Therefore the working capital adjustment as claimed by the Assessee should be allowed. We hold and direct accordingly.” 20. We notice that the Delhi bench of Tribunal has held in the case

AMC COOKWARE (INDIA) PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(2), BANGALORE

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

ITA 182/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 Nov 2021AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K

For Appellant: Shri K.P. Srinivas, CAFor Respondent: Shri Deva Rathna Kumar, CIT (DR)

transfer pricing adjustments. Aggrieved, the appellant filed its objections before the Hon'ble Dispute Resolution Panel, Bangalore ['the DRP']. Concurrently, the learned TPO initiated rectification proceedings and vide order u/s 92CA(5) r.w.s 154

CONTINUSERVE SOFTECH INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

ITA 242/BANG/2021[2016-17]Status: DisposedITAT Bangalore23 Sept 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.242/Bang/2021 Assessment Year : 2016-17 Vs. Dcit, M/S. Continuserve Softech India Pvt. Ltd., Circle – 2(1)(1), Prathik Tech Park, 2Nd & 3Rd Floor, Bengaluru. Sy. No.93/1, Veerasandra Village, Attibele Hobli, Hosur Road, Electronic City Phase 1, Bengaluru – 560 100. Pan : Aaacc 8342 A Assessee Respondent Assessee By : Shri. Darpan Kirpalani, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 22.09.2022 Date Of Pronouncement : 23.09.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Darpan Kirpalani, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 92Section 92(1)Section 92B(1)

rectification application u/s. 154 of the Income tax Act, 1961 before the TPO, with necessary documentary proof thereof.” 2.27.2 Considering the above, the TPO is directed to verify the computation of margins as provided by the assessee and if the assessee with necessary documentary proves the computation the same may be rectified. Otherwise, the TPO should adopt correct m rains

SAN DISK INDIA DEVICE DESIGN CENTRE PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 543/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

154 of the Act, the adjustments to the international transactions of provision of SWD and MS services were rectified to Rs.2,11,85,874/- and Rs.22,30,608/- respectively. Consequently, the aggregate TP adjustment was reworked to Rs.2,34,16,482/-. 3. In the draft assessment order dated 24.03.2014 passed by the AO, the aforesaid rectified Transfer Pricing (TP) adjustment

DCIT, BANGALORE vs. M/S SANDISK INDIA DEVICE DESIGN CENTRE PRIVATE LIMITED, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 341/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

154 of the Act, the adjustments to the international transactions of provision of SWD and MS services were rectified to Rs.2,11,85,874/- and Rs.22,30,608/- respectively. Consequently, the aggregate TP adjustment was reworked to Rs.2,34,16,482/-. 3. In the draft assessment order dated 24.03.2014 passed by the AO, the aforesaid rectified Transfer Pricing (TP) adjustment

BIOCON LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal filed by assessee for assessment year

ITA 557/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

rectification application u/s. 154 was filed by the taxpayer, as the AO/TPO had not complied with DRP directions in relation to recomputing the ALP. Aggrieved by the order of the LdAO, assessee is in appeal before us. Ground No.1-2 are general in nature. Therefore do not require any adjudication. Page 11 of 51 IT(TP)A No. 230/Bang/2014

JCIT, BANGALORE vs. M/S BIOCON LTD.,, BANGALORE

In the result appeal filed by assessee for assessment year

ITA 558/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

rectification application u/s. 154 was filed by the taxpayer, as the AO/TPO had not complied with DRP directions in relation to recomputing the ALP. Aggrieved by the order of the LdAO, assessee is in appeal before us. Ground No.1-2 are general in nature. Therefore do not require any adjudication. Page 11 of 51 IT(TP)A No. 230/Bang/2014

M/S. BATEMAN ENGINEERING (INDIA) PRIVATE LIMITED,BENGALURU vs. COMMISSIONER OF INCOME TAX, (APPEALS)-1,, BENGALURU

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

ITA 1139/BANG/2018[2008-09]Status: DisposedITAT Bangalore30 Jun 2022AY 2008-09

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Years : 2008-09

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Narayana K.R. Addl.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 154Section 92C

u/s. 92CA(5) RWS 154 of the Act, dated 19.01.2012 passed by the Deputy CIT (Transfer Pricing)-V, Bangalore, rectifying the original order under Section 92CA of the Act, dated 31-10-2011. Each order is independent and has to be challenged by way of separate proceedings. The appellant, by filing an appeal against one specific order, cannot challenge

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 556/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11 to 14 are not pressed before us and hence dismissed. 17. Ground No.15 regarding interest u/s. 234C of the Act is consequential in nature and does not require adjudication. IT(TP)A No.492 & 451/B/2015

ITO, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 402/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

rectification order u/s. 154 of the Act dated 13.6.2018 granting the relief. Accordingly this ground is not pressed and dismissed as such. 16. Grounds No.11 to 14 are not pressed before us and hence dismissed. 17. Ground No.15 regarding interest u/s. 234C of the Act is consequential in nature and does not require adjudication. IT(TP)A No.492 & 451/B/2015