WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. 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 N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.291/Bang/2022 Assessment Year: 2017-18

xv) The Learned AO/TPO/DRP have failed to apply the provisions of Rule 10B(4)&,(5) and 10CA(2) while selecting the criteria and filters. xvi) The Learned AO / TPO / DRP erred in not carrying out the adjustments like risk, working capital, et:c., as required under law as well as the facts. xvii) The learned AO/TPO/DRP erred in rejecting

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

10) r.w.s. 144C(13) of the Act and hence liable to be quashed. IT(TP)A No.298/Bang/2024 Goldman Sachs Services Pvt. Ltd., Bangalore Page 2 of 14 1.2 Complete effect not given to the DRP's direction 1.2.1 The learned AO has made the following apparent error while giving effect of the order of the Hon'ble DRP: • The learned

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

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

xv) Aptus Software Labs Private Limited\n(xvi) Tata Consultancy Services Limited\n(xvii) Consilient Technologies Private Limited\n(xviii) Cybage Software Private Limited\n5.4 The average PLI/margin of the comparables companies was\ncomputed at 25.09% with respect to SWD Segment. Accordingly, an\nupward TP adjustment was made by the TPO for Rs. 2,88,03,369/- only

NTT DATA INFORMATION PROCESSING SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V.Vasudevan & Shri Laxmi Prasad Sahu

2 IT(TP)A No.293/Bang/2022. NTT DATA Information Processing Services Pvt.Ltd. 3. Ld. AO/TPO pursuant to the directions of the Hon'ble DRP, erred in making addition of INR 78,56,31,349 to total income of Appellant alleging that prices charged by the Appellant for software development services and IT enabled services rendered to its associated enterprises