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198 results for “transfer pricing”+ Reopening of Assessmentclear

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Mumbai974 Delhi703 Chennai287 Jaipur218 Bangalore198 Surat192 Ahmedabad163 Kolkata155 Hyderabad130 Chandigarh107 Indore90 Cochin83 Rajkot72 Karnataka71 Pune61 Calcutta51 Lucknow38 Raipur29 Nagpur27 Amritsar22 Guwahati19 Visakhapatnam15 Cuttack14 SC13 Agra11 Dehradun8 Patna6 Varanasi5 Jodhpur3 Allahabad3 Telangana3 Rajasthan2 T.S. THAKUR ROHINTON FALI NARIMAN1 Andhra Pradesh1 A.K. SIKRI ROHINTON FALI NARIMAN1 Ranchi1

Key Topics

Section 14897 Addition to Income73 Section 14761 Section 143(3)50 Section 133A37 Reopening of Assessment32 Section 153C29 Section 143(2)25 Section 132(4)22

SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

ITA 1481/BANG/2010[2006-07]Status: DisposedITAT Bangalore31 Mar 2016AY 2006-07

Bench: Shri. Abraham P. George

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. G. R. Reddy, CIT – DR -I

Section 144C(5)

Assessing Officer, after having referred the matter to the Transfer Pricing Officer, could not reopen or re-examine the transaction

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 330/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Oct 2020AY 2010-11

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

Showing 1–20 of 198 · Page 1 of 10

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Survey u/s 133A19

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar

Section 139Section 143(3)Section 148

transfer pricing adjustment was made during the course of original assessment proceedings. However, the AO has reopened the assessment of AY 2007-08 on noticing

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 804/BANG/2016[2011-12]Status: DisposedITAT Bangalore14 Oct 2020AY 2011-12

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar

Section 139Section 143(3)Section 148

transfer pricing adjustment was made during the course of original assessment proceedings. However, the AO has reopened the assessment of AY 2007-08 on noticing

M/S NIKE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 3321/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Oct 2020AY 2014-15

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar

Section 139Section 143(3)Section 148

transfer pricing adjustment was made during the course of original assessment proceedings. However, the AO has reopened the assessment of AY 2007-08 on noticing

M/S.NIKE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

ITA 739/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Oct 2020AY 2012-13

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

For Appellant: Shri N Venkatraman, K.R. Vasudevan, A.RFor Respondent: Smt. Neera Malhotra and Shri Muzaffar

Section 139Section 143(3)Section 148

transfer pricing adjustment was made during the course of original assessment proceedings. However, the AO has reopened the assessment of AY 2007-08 on noticing

M/S JINDAL ALUMINIUM LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee stands dismissed

ITA 919/BANG/2014[2005-06]Status: DisposedITAT Bangalore28 Sept 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P. Boazassessment Year : 2005-06

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri Harinder Kumar, CIT(A)-3

Section 142ASection 143(3)Section 147Section 80

price. 3. The learned CIT (Appeals) ought to have appreciated that there was no obligation on the part of the Appellant to declare the transaction in the return of income when the transaction did not result in any income/loss and accordingly he ought to have refrained from upholding reopening of the assessment as made by the assessing officer

M/S. THE HIMALAYA DRUG COMPANY,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 2248/BANG/2016[2012-13]Status: DisposedITAT Bangalore02 Nov 2020AY 2012-13

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

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Muzaffar Hussain, D.R

Section 143(3)Section 144C(1)Section 156

transfer pricing adjustment. When the matter reached ITAT, the Tribunal remitted the matter back to the TPO to consider the additional details filed by the petitioner before the ITAT. Accordingly the TPO passed a fresh order. Thereafter, the assessing officer passed a final assessment order, instead of passing draft assessment order. The Hon’ble High Court held the same

DCIT, BANGALORE vs. SHRI. JAGADISH N HINDUJA, BANGALORE

In the result, appeals filed by the revenue and COs filed by the assessee are dismissed

ITA 1373/BANG/2012[2006-07]Status: DisposedITAT Bangalore22 Jul 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2006-07 Shri Jagadish N. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aacph7291Q Appellant Respondent Assessment Year: 2006-07 Shri Sumir J. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aaeph5197H Appellant Respondent C.O. No.48/Bang/2013 (Arising Out Of Ita No.1373/Bang/2012) Assessment Year: 2006-07 Shri Jagadish N. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent C.O. No.49/Bang/2013 (Arising Out Of Ita No.1374/Bang/2012) Assessment Year: 2006-07 Shri Sumir J. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent Appellant By : Shri Susan Dolores George, D.R. Respondent By : Shri Ashok A Kulkarni, A.R.

For Appellant: Shri Susan Dolores George, D.RFor Respondent: Shri Ashok A Kulkarni, A.R

Section 147Section 148Section 2(22)(e)

reopening of assessment have no merit and fully covered against assessee by the judgementof Hon’ble Supreme Court cited (supra). Accordingly, all the above grounds of assessee relating to opening are dismissed. 10. In the result, both the COs 48 & 49/Bang/2013 are dismissed. ITA No.1373& 1374/Bang/2012:- Income by way of Deemed dividend: 11. Facts of the case are that during

DCIT, BANGALORE vs. SHRI. SUMIR J HINDUJA, BANGALORE

In the result, appeals filed by the revenue and COs filed by the assessee are dismissed

ITA 1374/BANG/2012[2006-07]Status: DisposedITAT Bangalore22 Jul 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2006-07 Shri Jagadish N. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aacph7291Q Appellant Respondent Assessment Year: 2006-07 Shri Sumir J. Hinduja Deputy Commissioner Of Income- No.7 & 12, Industrial Suburb Tax Tumkur Road Vs. Circle 11(3) Yeshwanthpur Bangalore Bangalore 560 022 Pan No.Aaeph5197H Appellant Respondent C.O. No.48/Bang/2013 (Arising Out Of Ita No.1373/Bang/2012) Assessment Year: 2006-07 Shri Jagadish N. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent C.O. No.49/Bang/2013 (Arising Out Of Ita No.1374/Bang/2012) Assessment Year: 2006-07 Shri Sumir J. Hinduja Vs. Dcit, Circl-11(3),Bangalore Appellant Respondent Appellant By : Shri Susan Dolores George, D.R. Respondent By : Shri Ashok A Kulkarni, A.R.

For Appellant: Shri Susan Dolores George, D.RFor Respondent: Shri Ashok A Kulkarni, A.R

Section 147Section 148Section 2(22)(e)

reopening of assessment have no merit and fully covered against assessee by the judgementof Hon’ble Supreme Court cited (supra). Accordingly, all the above grounds of assessee relating to opening are dismissed. 10. In the result, both the COs 48 & 49/Bang/2013 are dismissed. ITA No.1373& 1374/Bang/2012:- Income by way of Deemed dividend: 11. Facts of the case are that during

NVIDIA GRAPHICS PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), BANGALORE

In the result, appeal filed by the assessee s party allowed

ITA 1111/BANG/2024[2014-15]Status: DisposedITAT Bangalore23 Oct 2024AY 2014-15

Bench: Shri George George K & Ms. Padmavathi. Sr Assessment Year : 2014-15 M/S. Nvidia Graphics Pvt. Ltd., Vs. Acit, Mahadevpura Village, Central Circle – 2(4), K. R. Puram Hobli, Marathalli Bangalore. Bagmane Goldstone Building, North Tower, Mahadevpura S.O, Bangalore – 560 048. Pan : Aabcn 9200 H Appellant Respondent Assessee By : Shri. Nageshwar Rao, Advocate Revenue By : Ms. Neha Sahay, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 17.10.2024 Date Of Pronouncement : 23.10.2024

For Appellant: Shri. Nageshwar Rao, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bengaluru

Section 143(3)Section 147Section 148Section 234BSection 234CSection 250Section 271(1)(c)Section 28

reopening (reference page 2 of assessment order). (iv) (iv)Further, it is also pertinent to note that the original assessment order passed under section 143(3) of the Act r.w.s. 144C of the Act for AY 2014-15 does not examine , discuss or form any opinion in respect of the aspect of receipt of free of cost assets/assets received

SRI RATHAN BABULAL LATH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

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

ITA 157/BANG/2020[2009-10]Status: DisposedITAT Bangalore05 Aug 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2009-10

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Vilas V. Shinde, D.R

Section 132Section 153A

price list itself could be the subject matter of cross- examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross- examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before this Court in Civil Appeal

SHRI M. THIMMEGOWDA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, both the appeals by the assessee are partly allowed

ITA 1036/BANG/2019[2006-07]Status: DisposedITAT Bangalore20 Apr 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

reopened, the assessing authority can take note of the income ITA Nos.1035 & 1036/Bang/2019 Page 20 of 78 disclosed in the earlier return, any undisclosed income found during search and also any other income which is not disclosed in the earlier return or which is not unearthed during the search, in order to find out what is the 'total income

SHRI M. THIMMEGOWDA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), BANGALORE

In the result, both the appeals by the assessee are partly allowed

ITA 1035/BANG/2019[2007-08]Status: DisposedITAT Bangalore20 Apr 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

reopened, the assessing authority can take note of the income ITA Nos.1035 & 1036/Bang/2019 Page 20 of 78 disclosed in the earlier return, any undisclosed income found during search and also any other income which is not disclosed in the earlier return or which is not unearthed during the search, in order to find out what is the 'total income

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, all the four appeals filed by the assessee are allowed

ITA 2374/BANG/2018[2013-14]Status: DisposedITAT Bangalore08 Apr 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

reopening of assessment and ground nos. 7 and 8 are on this aspect that the assessment order passed by the AO u/s. 144 is bad in law because the preconditions of section 144 are not complied with. Thereafter, he submitted that the remaining grounds are in respect of merit of the addition and charging of interest. 7. First he made

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, all the four appeals filed by the assessee are allowed

ITA 2373/BANG/2018[2012-13]Status: DisposedITAT Bangalore08 Apr 2019AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

reopening of assessment and ground nos. 7 and 8 are on this aspect that the assessment order passed by the AO u/s. 144 is bad in law because the preconditions of section 144 are not complied with. Thereafter, he submitted that the remaining grounds are in respect of merit of the addition and charging of interest. 7. First he made

LAXMIPAT DUDHERIA ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, all the four appeals filed by the assessee are allowed

ITA 2375/BANG/2018[2014-15]Status: DisposedITAT Bangalore08 Apr 2019AY 2014-15

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

reopening of assessment and ground nos. 7 and 8 are on this aspect that the assessment order passed by the AO u/s. 144 is bad in law because the preconditions of section 144 are not complied with. Thereafter, he submitted that the remaining grounds are in respect of merit of the addition and charging of interest. 7. First he made

LAXMIPAT DUDHERIA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

In the result, all the four appeals filed by the assessee are allowed

ITA 2376/BANG/2018[2015-16]Status: DisposedITAT Bangalore08 Apr 2019AY 2015-16

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

For Respondent: Shri K.R. Pradeep, Advocate &

Section 144Section 147Section 148Section 234BSection 234DSection 68Section 69C

reopening of assessment and ground nos. 7 and 8 are on this aspect that the assessment order passed by the AO u/s. 144 is bad in law because the preconditions of section 144 are not complied with. Thereafter, he submitted that the remaining grounds are in respect of merit of the addition and charging of interest. 7. First he made

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

ITA 108/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

assessing officer to assess the same, if the assessee disputes the same subsequently with corroborative evidences. 10.7. The Hon'ble Bombay High Court has dealt with this issue in case of Balmukund Acharya (310 ITR 310), wherein it was held as under:- "31. Having said so, we must observe that the Apex Court and the various High Courts have ruled

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

ITA 109/BANG/2022[2018-19]Status: DisposedITAT Bangalore14 Nov 2022AY 2018-19

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

assessing officer to assess the same, if the assessee disputes the same subsequently with corroborative evidences. 10.7. The Hon'ble Bombay High Court has dealt with this issue in case of Balmukund Acharya (310 ITR 310), wherein it was held as under:- "31. Having said so, we must observe that the Apex Court and the various High Courts have ruled

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

ITA 107/BANG/2022[2016-17]Status: DisposedITAT Bangalore14 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

assessing officer to assess the same, if the assessee disputes the same subsequently with corroborative evidences. 10.7. The Hon'ble Bombay High Court has dealt with this issue in case of Balmukund Acharya (310 ITR 310), wherein it was held as under:- "31. Having said so, we must observe that the Apex Court and the various High Courts have ruled