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

In the result, Both the C

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

E R Per Shri A. K. Garodia, Accountant Member Out of this bunch of six appeals and two Cos. for various years, the issue involved is one and common as to whether the Compulsorily Convertible Debentures (CCDs) are debt or equity and whether interest on CCDs is an allowable expenditure and if allowable then the amount allowable

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

In the result, Both the C

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

E R Per Shri A. K. Garodia, Accountant Member Out of this bunch of six appeals and two Cos. for various years, the issue involved is one and common as to whether the Compulsorily Convertible Debentures (CCDs) are debt or equity and whether interest on CCDs is an allowable expenditure and if allowable then the amount allowable

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

Bench: Shri. Abraham P. George

13 ITR (Trib) 422 (Mumbai) (page 432) : "We find that the basic reason of the Transfer Pricing Officer's determination of the arm's length price of the services received under cost contribution arrangement as 'nil' is his perception that the asses see did not need these services at all, as the assessee had sufficient experts of IT(TP)A.1481/B/2010

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

E), dated the 29th October, 2020, except as respects things done or omitted to be done before such supersession, the Central Government hereby specifies, for the completion or compliance of action referred to in- (A) clause (a) of sub-section (1) of section 3 of the Act,\ni. the 30th day of March, 2021 shall be the end date

SHRI. KOLA VENKAT RAMA NAIDU,BANGALORE vs. THE COMMISSIONER OF INCOME TAX (APPEALS) - 6, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by the assessee is directed against order of the CIT(A) dated 21.11.2019. The assessee has raised following grounds of appeal:- The impugned order dated 16.11.2019 passed by the (2) Assistant Commissioner of Income Tax, Appeal - 6 under section 250 of the Income Tax Act 1961 for assessment year

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together

M/S. ACER INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

13) Due date for passing final assessment order u/s 153(1) r.w.s 3rd proviso to the said 31.03.2012 section. 6. To adjudicate the addition ground, the relevant statutory provisions have to be seen. IT(TP)A Nos.502 & 2837/Bang/2017 Page 5 of 45 Time limit for completion of assessments and reassessments. 153. (1) No order of assessment shall be made under

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the assessment order dated 20/06/2024 in DIN No. ITBA/AST/S/143(3)/2024-25/ 1065988655(1) for the assessment year 2020-21. 2. The issues raised by the assessee in Ground Nos. 1 to 3 of the appeal are general in nature and therefore, the same

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

13 of 33 (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section (2) exceeds the value adopted or assessed or assessable by the stamp valuation authority referred to in sub-section (1), the value so adopted or assessed or assessable by such authority shall be taken as the full value

MFX INFOTECH PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

e-assessment centre dated 22.04.2021 passed under Section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act) for the assessment year (AY) 2016-17. 2. The assessee raised the following concise grounds of appeal: . M/s. MFX Infotech Pvt. Ltd 2 “General Grounds 1. The orders passed by the learned Deputy Commissioner of Income-tax Transfer Pricing

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by the assessee is directed against the final assessment order passed by DCIT, Circle-1(1), Bangalore. The assessee has raised following grounds of appeal:- The grounds mentioned herein below are independent and without prejudice to one another. 1. That, orders passed by the Deputy Commissioner of Income-tax, Circle 1

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

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")

E-Zest Solutions Limited c) Benchmark IT Solutions India Private Limited d) Smartcloud Infoservices Private Limited II. IT enabled Services Segment- a) Hello Information Services Private Limited b) Digicall Global Private Limited Other than Transfer Pricing - 12. That the Learned DRP erred in confirming the action of the Learned AO in disallowing deduction claimed under section 35AC

DCIT, BANGALORE vs. M/S SANDISK INDIA DEVICE DESIGN CENTRE PRIVATE LIMITED, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

E R Per N. V. VASUDEVAN, Vice President: IT(TP)A No.341/Bang/2015 is an appeal by the Revenue while IT(TP)A No.543/Bang/2015 is an appeal by the assessee. Both these appeals are directed against the final Order of Assessment dated 30.01.2015 passed by the ITO, Ward – 6(1)(1), Bengaluru, under section 143(3) r.w.s. 144C(13

SAN DISK INDIA DEVICE DESIGN CENTRE PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

E R Per N. V. VASUDEVAN, Vice President: IT(TP)A No.341/Bang/2015 is an appeal by the Revenue while IT(TP)A No.543/Bang/2015 is an appeal by the assessee. Both these appeals are directed against the final Order of Assessment dated 30.01.2015 passed by the ITO, Ward – 6(1)(1), Bengaluru, under section 143(3) r.w.s. 144C(13

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

13) Due date for passing final assessment order u/s 153(1) r.w.s 3rd proviso to the said 31.03.2012 section. 6. To adjudicate the addition ground, the relevant statutory provisions have to be seen. Time limit for completion of assessments and reassessments. 153. (1) No order of assessment shall be made under section 143 or section 144 at any time after