M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

transferred by the Appellant to Relay B.V. 8. The learned AO and the Hon'ble DRP have erred in disregarding the comparable uncontrolled transaction of sale of shares of United Spirits Limited by unrelated individual shareholders at the same price of INR 1440 per share by erroneously assuming that there existed separate compensation to such unrelated individual shareholders without there

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

131 of the IT Act has been recorded and\nit is confirmed by Sri NA Harris the Managing partner of\nthe firm that the land with which the JDA is entered is a\nstock in trade.\n4. Sri NA Harris also confirmed that the purpose of floating\nthe firm is for real estate and development business

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

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

Bench: Shri George George K. & Ms. Padmavathy S

TRANSFER OF PRODUCT ENGINEERING SERVICES (PES) BUSINESS TO L&T TECHNOLOGY SERVICES LIMITED (LTTSL) AND WINDING UP OF GDA TECHNOLOGIES INC. (GDA INC.) As part of business restructuring undertaken within L&T Group, it was decided to consolidate the engineering services business under a separate subsidiary of L&T, L&T Technology Services Ltd. (LTTSL). Pursuant to this, the Company

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

131(1) of the Act, again confirmed the non-genuine cash purchases but reduced the ratio from 25% to 20% of cash purchases. 2.14 The assessee later attempted to retract the admission, but the retraction was made after a long delay of over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, the appeals of the assessee for Assessment Years

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

131(1) of the Act, again confirmed the non-genuine cash purchases but reduced the ratio from 25% to 20% of cash purchases. 2.14 The assessee later attempted to retract the admission, but the retraction was made after a long delay of over 14 months and was not supported by any corroborative evidence. The AO found that statements recorded under

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded under

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded under

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded under

BYSANI ADINARAYAGUPATHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded under

BYSANI SRINATH MAMATHA,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE-1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded under

BYSANI ADINARAYAGUPTHA SRINATH,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CENTRAL CIRCLE 1(3), BENGALURU

In the result, all the appeals of the assessee for A

131(1) of the Act,\nagain confirmed the non-genuine cash purchases but reduced the ratio\nfrom 25% to 20% of cash purchases.\n\n2.14 The assessee later attempted to retract the admission, but the\nretraction was made after a long delay of over 14 months and was not\nsupported by any corroborative evidence. The AO found that statements\nrecorded

EMC SOFTWARE AND SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 2, BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes as per the terms mentioned above

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

Section 133(6) notice cannot take precedence over the annual report. In the present case, as stated above, the annual report clearly reflects that the Company renders diverse services which are high end and not comparable to the software development services rendered by the Appellant. In Airlinq Technology Pvt. Ltd. v. DCIT (Order dated 28.07.2022 passed by this

M/S. PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

transfer pricing (‘TP’) documentation maintained by the Appellant under Section 92D of the Act, in good faith and with due diligence; 6.2. Rejecting the filters selected by the Appellant as captured in the TP documentation and adopting certain addition filters which are not in accordance with the jurisprudence laid down by various appellate forums; 6.3. Application of related party transaction

MOHAMMED ABDUL NAJEEB,GULBARGA, KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

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

131(1)(d) of the\nIncome Tax Act, 1961, as per the provisions\nof Section 142A. The only reasonable and\nlogical inference is that the assessing\nofficer has, without application of mind to\nthe seized materials, analysis of the seized\nmaterials, referred to Department\nValuation Officer, only to get additional\ntime for making assessment which is\ncontrary to the provisions

MICROCHIP TECHNOLOGY (INDIA) PRIVATE LIMITED ,BENGALURU vs. DCIT CIRCLE 4(1)(1), BMTC BUILDING, KORAMANGALA

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19

transfer pricing order, the Ld.AO issued 142(1) notice on 27/08/21 to verify the ESOP expenses claimed by the assessee amounting to Rs.9,90,81,453/- on payment basis u/s. 37 of the act. The assessee vide correspondence dated 09.09.2021 submitted details, but was silent on the issue. The Ld.AO recorded that the assessee did not file any supporting evidence