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

price allocation. Based on such valuation, the total purchase consideration was allocated to identifiable intangible assets such as business contracts, technology, and goodwill, and depreciation was claimed under section 32 of the Act. ITA Nos.290 - 294/Bang/2025 Page 23 of 53 30.1 The learned AR pointed out that the AO originally disallowed the claim on the ground that the assets were

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

142(1) on various dates were issued and served electronically on the appellant. In compliance to the notices, appellant e-filed detailed replies on 30.11.2021, 22.01.2022 and 09.03.2022. The appellant in response to these notices, stated that the provisions of section 50C are not applicable in case of the appellant as the case of the appellant is covered

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

transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment

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

pricing matters 5. Disallowance of reimbursement of salary cost of personnel transferred from overseas group entities under section 40(a)(i) of the Act 5.1. That on the facts and in the circumstances of the case, the Learned AO and the Learned Panel have erred in making / sustaining the disallowance of INR 25,13,98,099. Without prejudice

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

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

price allocation. Based on such valuation, the total purchase consideration was allocated to identifiable intangible assets such as business contracts, technology, and goodwill, and depreciation was claimed under section 32 of the Act. 30.1 The learned AR pointed out that the AO originally disallowed the claim on the ground that the assets were not eligible intangible assets. However

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")

142(1) were issued and served on the assessee. 2.2 The Ld.AO noted that, during the F.Y. 2015-16, the assessee company had international transactions as per Section 92 of the Income-tax Act, 1961. According to Section 92CA of the Income- tax Act, 1961, the case was referred to the Transfer Pricing

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment made in respect of reimbursement of expenses. It is a fact that during the year under consideration, the TPO had held in the original assessment proceedings that the reimbursement of expenses is related to the business activities of the assessee and IT(TP)A Nos.330/Bang/2015, 804/Bang/2016 356/Bang/2017, 739/Bang/2017 & 3321/Bang/2018 M/s. Nike India Private Limited, Bangalore Page

M/S NIKE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment made in respect of reimbursement of expenses. It is a fact that during the year under consideration, the TPO had held in the original assessment proceedings that the reimbursement of expenses is related to the business activities of the assessee and IT(TP)A Nos.330/Bang/2015, 804/Bang/2016 356/Bang/2017, 739/Bang/2017 & 3321/Bang/2018 M/s. Nike India Private Limited, Bangalore Page

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

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment made in respect of reimbursement of expenses. It is a fact that during the year under consideration, the TPO had held in the original assessment proceedings that the reimbursement of expenses is related to the business activities of the assessee and IT(TP)A Nos.330/Bang/2015, 804/Bang/2016 356/Bang/2017, 739/Bang/2017 & 3321/Bang/2018 M/s. Nike India Private Limited, Bangalore Page

NIKE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee for AY 2007-08 is allowed and all other appeals of the assessee are treated as partly allowed

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

transfer pricing adjustment made in respect of reimbursement of expenses. It is a fact that during the year under consideration, the TPO had held in the original assessment proceedings that the reimbursement of expenses is related to the business activities of the assessee and IT(TP)A Nos.330/Bang/2015, 804/Bang/2016 356/Bang/2017, 739/Bang/2017 & 3321/Bang/2018 M/s. Nike India Private Limited, Bangalore Page

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

Section 92CA(1) to the Transfer Pricing Officer (TPO) for the determination of Arm's Length Price (ALP) of the international transactions. The TPO noted that as per the Transfer Pricing (TP) documents furnished for the Assessment Year 2015-2016, the Assessee had entered into the following International Transactions with its AEs: International Transactions as per 3CEB Particulars Received/ Receivables

M/S. THE HIMALAYA DRUG COMPANY,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

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

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

Section 92CA of the Act; viz. at the 1st para on page 3 and 6, last para of page 4, 2nd para on page 5, etc. The TPO, however, rejected TNMM as the MAM and adopted CPM for determination of ALP of sale of finished goods to the assessee for the reason that, even though the products sold

M/S THE HIMALAYA DRUG COMPANY,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal for Assessment Year 2011-12 is partly allowed

Bench: Shri Jason P Boaz & Shri Laliet Kumarit(Tp)A No.187/Bang/2015 Assessment Year : 2010-11

Section 92CA of the Act; viz. at the 1stpara on page 3 and 6, last para of page 4, 2ndpara on page 5, etc. The TPO, however, rejected TNMM as the MAM and adopted CPM for determination of ALP of sale of finished goods to the assessee for the reason that, even though the products sold in the domestic consumer

THE HIMALAYA DRUG COMPANY,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX(OSD), CIRCLE-6(1)(1), BENGALURU

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

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

Section 92CA of the Act; viz. at the 1st para on page 3 and 6, last para of page 4, 2nd para on page 5, etc. The TPO, however, rejected TNMM as the MAM and adopted CPM for determination of ALP of sale of finished goods to the assessee for the reason that, even though the products sold

THE HIMALAYA DRUG COMPANY ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

Section 92CA of the Act; viz. at the 1st para on page 3 and 6, last para of page 4, 2nd para on page 5, etc. The TPO, however, rejected TNMM as the MAM and adopted CPM for determination of ALP of sale of finished goods to the assessee for the reason that, even though the products sold

M/S. THE HIMALAYA DRUG COMPANY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(2)(1), BENGALURU

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

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

Section 92CA of the Act; viz. at the 1st para on page 3 and 6, last para of page 4, 2nd para on page 5, etc. The TPO, however, rejected TNMM as the MAM and adopted CPM for determination of ALP of sale of finished goods to the assessee for the reason that, even though the products sold

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

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

142(1) was also issued on 9.6.2017 calling for details of Large Specified Domestic Transactions (Form 3CEB) for limited scrutiny proceedings and the details and explanations were provided by the assessee vide letters dated 9.10.2017 & 12.10.2017. Assessment was completed u/s. 143(3) on 30.10.2017. 4. The PCIT noticed that one of the parameters was Transfer Pricing Risk Parameter which