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4 results for “transfer pricing”+ Section 115A(1)(b)clear

Sorted by relevance

Mumbai69Delhi36Bangalore4Chennai3

Key Topics

Section 1956Section 2015Section 201(1)4Deduction4Double Taxation/DTAA4Survey u/s 133A4Section 133A3Section 402Section 9(1)(vii)2

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

In the result, all these 4 appeals filed by the Revenue are dismissed

ITA 1296/BANG/2024[2017-18]Status: DisposedITAT Bangalore24 Jul 2025AY 2017-18
For Appellant: Dr. Divya K.J., CIT(DR)(ITAT), BengaluruFor Respondent: Shri Suryanarayan, AR
Section 133ASection 195Section 201Section 201(1)

b) accrues or arises or is deemed to accrue or arise to him in India\nduring such year.\n\n10.1 Breaking down sub-section (2) into its components, it covers income\nof a non-resident from whatever source derived which (i) is received in India;\n(ii) accrues in India; (iii) arises in India; (iv) is deemed to be received

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

In the result, all these 4 appeals filed by the Revenue are dismissed

ITA 1294/BANG/2024[2014-15]Status: DisposedITAT Bangalore24 Jul 2025AY 2014-15
For Appellant: Dr. Divya K.J., CIT(DR)(ITAT), BengaluruFor Respondent: Shri Suryanarayan, AR
Section 133ASection 195Section 201Section 201(1)

b) accrues or arises or is deemed to accrue or arise to him in India\nduring such year.\n\n10.1 Breaking down sub-section (2) into its components, it covers income\nof a non-resident from whatever source derived which (i) is received in India;\n(ii) accrues in India; (iii) arises in India; (iv) is deemed to be received

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

In the result, all these 4 appeals filed by the Revenue are dismissed

ITA 1295/BANG/2024[2016-17]Status: DisposedITAT Bangalore24 Jul 2025AY 2016-17
Section 133ASection 195Section 201Section 201(1)

b) accrues or arises or is deemed to accrue or arise to him in India\nduring such year.\n10.1 Breaking down sub-section (2) into its components, it covers income\nof a non-resident from whatever source derived which (i) is received in India;\n(ii) accrues in India; (iii) arises in India; (iv) is deemed to be received

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

ITA 1243/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 Apr 2025AY 2015-16

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

For Appellant: Smt. Manasa Ananthan, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 143(3)Section 195Section 201Section 201(1)Section 250Section 40Section 9(1)(vii)

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