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193 results for “transfer pricing”+ Section 113clear

Sorted by relevance

Delhi711Mumbai538Karnataka298Bangalore193Chennai148Ahmedabad135Hyderabad127Jaipur91Kolkata73Cochin72Chandigarh63Pune55Calcutta52Indore50Raipur26Lucknow23Visakhapatnam22Guwahati18Cuttack17Rajkot15Surat14Telangana12SC12Dehradun9Nagpur8Rajasthan5Varanasi4Amritsar4Agra2Jodhpur2D.K. JAIN JAGDISH SINGH KHEHAR1Kerala1Andhra Pradesh1

Key Topics

Addition to Income69Section 143(3)61Transfer Pricing46Section 92C42Section 14829Comparables/TP28Section 133A25Section 153C24Deduction

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

ITA 84/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

ITA 63/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

Showing 1–20 of 193 · Page 1 of 10

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24
Section 143(2)20
Disallowance20
Section 2(15)18

M/S. ATMECS TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-1(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 187/BANG/2021[2016-17]Status: DisposedITAT Bangalore20 Dec 2021AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.187/Bang/2021 Assessment Year : 2016-17 M/S. Atmecs Technologies Private Limited, Vs. The Income Tax Officer, Flat No.301, M J Towers, H-No.8-2-698, Ward -1(1)(1), Road No.12, Bengaluru. Banjara Hills, Hyderabad, Telangana – 500 034. Pan : Aamca 0792 J Appellant Respondent Appellant By : Shri. P.V.S.S.Prasad, Ca Respondent By : Shri. Arunkumar, Cit(Tp-2)(Dr)(Itat), Bengaluru Date Of Hearing : 14.12.2021 Date Of Pronouncement : 20.12.2021 O R D E R Per N. V. Vasudevan: This Appeal By The Assessee Is Directed Against The Final Order Of Assessment Dated 30.3.2021 By The National E-Assessment Centre, Delhi, (Hereinafter Referred To As The Assessing Officer, “Ao” In Short) Passed U/S.143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Act) In Relation To Ay 2016-2017. 2. The Assessee In Engaged In The Business Of Provision Of Software Development Services (Swd Services), To It’S Associated Enterprises

For Appellant: Shri. P.V.S.S.Prasad, CAFor Respondent: Shri. Arunkumar, CIT(TP-2)(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 92(1)Section 92B(1)Section 92C

section of the UN TP Manual which states as under: "...10.3.1.3. The regulation prescribes mandatory annual filing requirements as well as maintenance of contemporaneous documentation by the taxpayer in case international transactions between associated enterprises cross a threshold and contains stringent penalty implications in case of noncompliance. The primary onus of proving arm's length price of the transaction lies

M/S SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

ITA 561/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

Pricing Page 15 of 29 IT(TP)A Nos. 561 & 437/Bang/2015 Officer before the said date, or a reference under sub- section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred

D.C.I.T., BANGALORE vs. M/S SAP LABS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed

ITA 437/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.

For Respondent: Shri Arun Kumar, CIT DR
Section 92D

Pricing Page 15 of 29 IT(TP)A Nos. 561 & 437/Bang/2015 Officer before the said date, or a reference under sub- section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred

DCIT, BANGALORE vs. M/S TATA POWER SOLAR SYSTEMS LTD.,, BANGALORE

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 548/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 548/Bang/2016 Assessment Year : 2011-12 M/S. Tata Power Solar The Deputy Systems Ltd., Commissioner Of 78, Electronic City, Income Tax, Hosur Road, Circle – 7(1)(1), Bangalore – 560 100. Bangalore. Vs. Pan: Aaact4660J Appellant Respondent & It(Tp)A No. 699/Bang/2016 Assessment Year : 2011-12 (By Assessee) Assessee By : Shri Kanchun Kaushal, Ca : Shri Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 14-02-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Cross Appeals By Assessee & Revenue Arises Out Of Final Assessment Order Dated 28.01.2016 Passed By The Ld.Dcit, Circle -7 (1)(1), Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal: It(Tp)A No. 548/Bang/2016 (Revenue’S Appeal): “1. The Directions Of The Dispute Resolution Panel Are Opposed To Law & Facts Of The Case.

For Appellant: Shri Kanchun Kaushal, CA
Section 144C

Pricing Officer before the said date, or a reference under sub-section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case

TATA POWER SOLAR SYSTEMS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 699/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 548/Bang/2016 Assessment Year : 2011-12 M/S. Tata Power Solar The Deputy Systems Ltd., Commissioner Of 78, Electronic City, Income Tax, Hosur Road, Circle – 7(1)(1), Bangalore – 560 100. Bangalore. Vs. Pan: Aaact4660J Appellant Respondent & It(Tp)A No. 699/Bang/2016 Assessment Year : 2011-12 (By Assessee) Assessee By : Shri Kanchun Kaushal, Ca : Shri Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 14-02-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Cross Appeals By Assessee & Revenue Arises Out Of Final Assessment Order Dated 28.01.2016 Passed By The Ld.Dcit, Circle -7 (1)(1), Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal: It(Tp)A No. 548/Bang/2016 (Revenue’S Appeal): “1. The Directions Of The Dispute Resolution Panel Are Opposed To Law & Facts Of The Case.

For Appellant: Shri Kanchun Kaushal, CA
Section 144C

Pricing Officer before the said date, or a reference under sub-section (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case

MATCHMOVE INDIA PRIVATE LIMITED,BANGALORE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND INCOME TAX OFFICER, WARD 4(1)(3), BANGALORE, BANGALORE

In the result, ground no. 4 of the Appeal is allowed with above direction

ITA 2255/BANG/2024[2021-22]Status: DisposedITAT Bangalore08 Apr 2026AY 2021-22

Bench: Shri Prashant Maharishi & Shri Sounadararajan K.Ittpa No. 2255/Bang/2024 Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K. J – CIT
Section 143(3)

Transfer Pricing Grounds: 3. Adjustment on account of re-determination of ALP for software development services rendered by the Appellant to its AEs amounting to INR 10,25,38,320 3.1. Erred by not accepting the economic analysis undertaken by the Appellant in accordance with the Act and the corresponding Rules, conducting a fresh economic analysis for the determination

M/S CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

In the result, the appeal is partly allowed

ITA 129/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2014-15 M/S. Continental Automotive Vs. Dcit, Components India Pvt. Ltd., Circle – 2(1)(1), Plot No.53B, Bommasandra Industrial Bengaluru. Area, Hosur Road, Attibele Hobli, Anekal Taluk, Bengaluru–560 099. Pan : Aakcs 9578 C Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Shri. Mudavathu Harish Chandra Naik, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 21.03.2022 Date Of Pronouncement : 29.03.2022 O R D E R

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Shri. Mudavathu Harish Chandra Naik, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

price by the TPO and the adjustment made: Arm’s Length Mean Mark-up 29.40% Operating Cost Rs.129,89,30,000/- Arm’s Length Price @129.40% of cost Rs.168,08,20,000/- Price Received Rs.1,38,06,40,000/- Shortfall being adjustment u/s. 92CA Rs.30,01,80,000/- 79. Aggrieved by the aforesaid determination

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals are partly allowed

ITA 1309/BANG/2010[2006-07]Status: DisposedITAT Bangalore22 Mar 2022AY 2006-07

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1309 & 1310/Bang/2010 Assessment Years : 2006-07 & 2007-08 M/S. Transworld Ict Solutions Pvt. Ltd., Vs. Dcit, Innovator, No.15, Hoody, Whitefield Road, Circle – 2(1), Mahadevapura Post, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 17.03.2022 Date Of Pronouncement : 22.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92Section 92(1)Section 92B(1)

section 92C(2) of the Act is effective from 1-10-2009 was clarificatory and denied the 5% rebate which ought to have been given as per the existing proviso for the respective years. 5. Appropriate Transfer Pricing Methodology: 5.1 The authorities below failed to appreciate that CPM is the appropriate methodology for determining the transfer pricing

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, both the appeals are partly allowed

ITA 1310/BANG/2010[2007-08]Status: DisposedITAT Bangalore22 Mar 2022AY 2007-08

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1309 & 1310/Bang/2010 Assessment Years : 2006-07 & 2007-08 M/S. Transworld Ict Solutions Pvt. Ltd., Vs. Dcit, Innovator, No.15, Hoody, Whitefield Road, Circle – 2(1), Mahadevapura Post, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 17.03.2022 Date Of Pronouncement : 22.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92Section 92(1)Section 92B(1)

section 92C(2) of the Act is effective from 1-10-2009 was clarificatory and denied the 5% rebate which ought to have been given as per the existing proviso for the respective years. 5. Appropriate Transfer Pricing Methodology: 5.1 The authorities below failed to appreciate that CPM is the appropriate methodology for determining the transfer pricing

SOFTLAYER TECHNOLOGIES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(2), BANGALORE

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

ITA 265/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Oct 2022AY 2016-17

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)
Section 143(3)Section 92C

section 92CA of the Income-tax Act, 1961 (‘the Act’) without appreciating that a) there is no amendment to the definition of "income" and charging or computation provision relating to income under the head "Profits & Gains of Business or Profession" do not refer to or include the amounts computed under Chapter X; and b) passing the orders without considering

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

transfer pricing analysis. The basis for the costs incurred, the activities for which they were incurred, and the benefit accruing to the Taxpayer from those activities must all be proved to determine first, whether, and how much, of such expenditure was for the purpose of benefit of the Taxpayer, and secondly, whether that amount meets ALP criterion. In the present

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

transfer pricing analysis. The basis for the costs incurred, the activities for which they were incurred, and the benefit accruing to the Taxpayer from those activities must all be proved to determine first, whether, and how much, of such expenditure was for the purpose of benefit of the Taxpayer, and secondly, whether that amount meets ALP criterion. In the present

CITRIX R & D INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands allowed partly as indicated herein above

ITA 220/BANG/2021[2016-17`]Status: DisposedITAT Bangalore25 Aug 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 220/Bang/2021 Assessment Year : 2016-17 M/S. Citrix R&D India Pvt. Ltd., The Deputy Prestige Dynasty, Commissioner Of Ground Floor, Income Tax, 33/2, Ulsoor Road, Circle – 2(1)(1), Bangalore – 560042. Vs. Bangalore. Pan: Aabcn3639C Appellant Respondent Assessee By : Shri Sumit Khurana, Ca Revenue By : Shri M. Mathivanan, Cit-Dr Date Of Hearing : 04-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Assessment Order Dated 30/03/2021 Passed By The National E-Assessment Centre, Delhi Relating To Assessment Year 2016-17 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another. 1. That The Order Passed By The Learned Ao To The Extent Prejudicial To The Appellant, Is Bad In Law & Liable To Be Quashed. Transfer Pricing - 2. That The National E-Assessment Centre, Delhi / Deputy Commissioner Of Income Tax, Circle 2(1)(1), Bangalore ("Assessing Officer" Or "Learned Ao") & The Dispute Resolution Panel - 1 ("Learned Panel" Or "Learned Drp")

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri M. Mathivanan, CIT-DR

section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :--- (a) to (d)…………. (e)transactional net margin method, by which,— (i) the net profit margin realised by the enterprise from an international transaction

M/S. ORIGAMI CELLULO PRIVATE LIMITED,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 5, BENGALURU

In the result, the appeal of the assessee is allowed

ITA 394/BANG/2020[2015-16]Status: DisposedITAT Bangalore15 Sept 2021AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2015-16

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Pradeep Kumar, CIT(DR-III)(ITAT), Bengaluru
Section 142(1)Section 143(2)Section 143(3)Section 263Section 40A(2)(b)Section 92A(2)Section 92C

Transfer Pricing risk parameter. On the other hand, the case was selected for limited scrutiny one of the reasons being mismatch in amount paid to related persons u/s. 40A(2)(b) reported in audit report and ITR. From a reading of these reasons, we are of the view that no prudent business person properly instructed in law would have inferred

M/S. EYGBS (INDIA ) LLP (EARLIER KNOWN AS EYGBS (INDIA) PRIVATE LIMITED),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(2), BANGALORE

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

ITA 2342/BANG/2019[2011-12]Status: DisposedITAT Bangalore23 Nov 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2342/Bang/2019 Assessment Year: 2011-12

For Appellant: Shri Rajan Vora, A.RFor Respondent: Smr. R. Premi, D.R
Section 10ASection 234B

transfer pricing adjustment suo-moto offered by the assessee. The relevant findings of Tribunal are as under:— '17. We have heard both the parties. Before proceeding further, it will be relevant to reproduce section 10A(1). "Section 10A. Special provision in respect of newly established undertakings in free trade zone, etc.—(1) Subject to the provisions of this section

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

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

ITA 2385/BANG/2019[2015-16]Status: DisposedITAT Bangalore05 Aug 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sumeet Khurana, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R
Section 133(6)Section 143(3)Section 144CSection 92D

transfer price once developed.” Furthermore, the Company is leading provider of Bluetooth Intellectual Property solutions (He referred page 1915 of Annual Report Compendium, expert thinking para) and is also providing digital video surveillance solutions based on the technology developed and for which company has filed patent application (He referred page 1871 & 1872 which is the Annual Report Compendium

M/S. PRAXAIR INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

ITA 199/BANG/2021[2015-16]Status: DisposedITAT Bangalore22 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Suryanarayana, Senior A.RFor Respondent: Shri K. Sankar Ganesh, D.R
Section 143Section 143(3)Section 92C

section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which do not require any adjudication

M/S PRAXAIR INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2 , BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

ITA 3336/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Suryanarayana, Senior A.RFor Respondent: Shri K. Sankar Ganesh, D.R
Section 143Section 143(3)Section 92C

section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which do not require any adjudication