M/S.FILTREX TECHNOLOGIES PRIVATE LTD.,,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appeal by the Assessee is treated as allowed for statistical purpose

Bench: Shri N.V Vasudevan & Shri Jason P Boazit(Tp)A Nos.469/Bang/2017 (Asst. Year – 2012-13) M/S Filtrex Technologies Pvt. Ltd., #36/4, Raghavendra Nagar, Near Ring Road, 4Th Cross, Hrbr Layout, Bangalore. Pan – Aaacf4091P. …..Appellant Vs. The Asst. Commissioner Of Income-Tax, Circle-(3)(1), Bengaluru. …. Respondent Appellant By : Shri Padmchand Khincha, C.A Respondent By : Shri C.H Sundar Rao, Cit(Dr) Date Of Hearing : 08-03-2018 Date Of Pronouncement : 11-04-2018 O R D E R

transfer pricing analysis without rejecting the TP analysis performed by the Appellant; iii.Rejecting TNMM applied by Appellant to justify its international transactions with AE on unjustifiable grounds; iv.Not appreciating that Appellant had adopted TNMM at the entity level, in which process, the royalty payment and IT(TP)ANo.469/B/17 12 management fee was considered and accordingly benchmarked; and v. Not appreciating

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

115A(1 A) shows that for the purposes of krIcome-tax copyright "computer software" is different from copyright in any "book" though both are literary works under the Copyright Act, 1957. Therefore, once the consideration is received by a non-resident for the transfer or all or any rights including the granting of a licence in respect of a patent

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRLCE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

transfer pricing exercise) cannot negate the nature of the transaction. It would lead to an absurd conclusion if, all else constant, the fact that no payment is demanded negates accrual of income to the overseas entity. Instead, the various factors concerning the determination of the real employment link continue to operate, and the consequent finding that provision of employees

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

transfer pricing exercise) cannot negate the nature of the transaction. It would lead to an absurd conclusion if, all else constant, the fact that no payment is demanded negates accrual of income to the overseas entity. Instead, the various factors concerning the determination of the real employment link continue to operate, and the consequent finding that provision of employees

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE - 1(1), BENGALURU vs. APPLIED MATERIALS INDIA PRIVATE LIMITED, BENGALURU

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

transfer pricing exercise) cannot negate the nature of the transaction. It would lead to an absurd conclusion if, all else constant, the fact that no payment is demanded negates accrual of income to the overseas entity. Instead, the various factors concerning the determination of the real employment link continue to operate, and the consequent finding that provision of employees

M/S IBM SINGAPORE PTE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTENATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeal filed by the assessee is partly allowed and the appeal of the revenue is dismissed

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2014-15

price of the computer programme as goods, either in a medium which stores the software or in a medium by which software is embedded in hardware, which may be then further resold by the distributor to the end-user in India, the distributor making a profit on such resale. Importantly, the distributor does not get the right

INCOME TAX OFFICER, INTERNATIONAL TAXATION, WARD-1(2), BENGLAURU, BENGALURU vs. UNITEDLEX INDIA PVT. LTD. (EARLIER KNOWN AS I-RUNWAY INDIA PRIVATE LIMITED), BENGALURU

In the result, appeal of the revenue is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year :2015-16

115A of the Act was applied being the higher rate as provided in section 206AA of the Act and the appropriate EC and SC is also applied. Before us, the revenue has raised various grounds on the merit of the case which in our opinion, has already been decided by this Tribunal in ITA No.229/Bang/2019 dated 27.4.2022 in the case

M/S AD2PRO MEDIA SOLUTIONS PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all the 14 appeals filed by the assessee are allowed

Bench: Shri A.K.Garodia & Shri P.K.Gadale(Ita Nos.490 To 503(Bang)/2019) (Assessment Years: 2011-12 To 2017-18) M/S Ad2Pro Media Solutions Pvt.Ltd., No.10, 2Nd Floor, Bannerghatta Road, J.P.Nagar-Iii Phase, Bangalore-560078 Appellant Vs The Deputy Commissioner Of Income Tax, (International Taxation) Circle-1(1), Bmtc Building, Koramangala, Bangalore-560095 Respondent

pricing taking feedback and inputs from Ad2pro India. o Final contract is sent to Client for review and acceptance. o Client reviews and sometimes may request for changes. o Once the contract is finalized it is executed between Client and Ad2pro India.  Existing Client References o In many case promotions of Ad2pro's services happens through references provided by existing