PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

2), Bengaluru ("Transfer Pricing Office / TPO") for determination of Arm's Length Price under section 92CA of the Act on 30.03.2022. Several notices were issued under section 142

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

142(1) of the Act along with show cause notice were issued and duly served upon the assessee. In response to these notices, the assessee company filed its submissions from time to time. The arguments and details furnished by the assessee company were carefully perused and taken into consideration by the AO. 5.1 During the course of assessment proceedings

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

142(1) were also issued. In the said\nnotice, the AO was seeking the explanation that whether the payment is hit\nby the proviso to section 2(15) r.w.s. 13(8) of the Act. Similarly, the AO had\nproposed to disallow certain amounts u/s. 43B of the Act. The assessee\nfiled their objection by stating that the proviso to section

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

142(1) were also issued. In the said\nnotice, the AO was seeking the explanation that whether the payment is hit\nby the proviso to section 2(15) r.w.s. 13(8) of the Act. Similarly, the AO had\nproposed to disallow certain amounts u/s. 43B of the Act. The assessee\nfiled their objection by stating that the proviso to section

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section (2

BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

Transfer Pricing\nOfficer\" shall have the same meaning as assigned to in the\nExplanation to section 92CA.]\n[(2) No order shall be made under sub-section (1) after the expiry of\ntwo years from the end of the financial year in which the order sought\nto be revised was passed.]\n(3) Not withstanding anything contained in sub-section

ADARSHA SOUHARDA SAHAKARI NIYAMIT SIRSI,SIRSI vs. PR. COMMISSIONER OF INCOME TAX, , HUBALLI

In the result the appeal filed by the assessee is allowed

Transfer Pricing Officer\"\nshall have the same meaning as assigned to in the Explanation to section\n92CA.]\n[(2) No order shall be made under sub-section (1) after the expiry of two\nyears from the end of the financial year in which the order sought to be\nrevised was passed.]\n(3) Not withstanding anything contained in sub-section

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\ndetermination of Arm's Length Price (ALP) of the international\ntransactions. The TPO noted that as per the Transfer Pricing (TP)\ndocuments furnished for the Assessment Year 2015-2016, the\nAssessee had entered into the following International Transactions\nwith its AEs:\nInternational Transactions as per 3CEB\nParticulars\nReceived/\nReceivables

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section (2

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

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, CIRC-2(1)(1), BANGALORE

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 342/Bang/2022 Assessment Year : 2017-18 M/S. Deliverhealth Solutions India Pvt. Ltd. (Earlier Known As Nuance Transcription Services India Pvt. Ltd.) The Joint First Floor, Block B, Commissioner Of Salarpuria Aura, Income Tax, Khata No. 434/170, Circle 2(1)(1), Marathahalli –Sarjapur Outer Vs. Bangalore. Ring Road, Kaverappa Layout, Kadubeesanahalli, Bangalore – 560 103. Pan: Aaacf3465F Appellant Respondent

transfer pricing study of the Appellant and using arbitrary filters for benchmarking the international transaction pertaining to ITeS. 4.1 That on facts and circumstances of the case and in law, the AO/DRP/TPO have erred in applying the turnover filter with lower limit of INR 1 Crore without appreciating that the Appellant's turnover was INR 233.97 crore, and therefore, ought

TRISHUL BUILDTECH INFRASTRUTURE (P) LTD.,,BANGALORE vs. JCIT, BANGALORE

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

2) on 26.9.2013 followed by a notice under section 142(1) of the Act to the amalgamating company. MSIL participated in the assessment proceedings of erstwhile amalgamating entity i.e. SPIL through its authorized representative and officers. The assessment was framed. Thereafter during the appellate proceedings before the Tribunal the assessee took an objection that final assessment order was passed

TRISHUL BUILDTECH INFRASTRUCTURE (P) LTD.,,BANGALORE vs. JCIT, BANGALORE

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

2) on 26.9.2013 followed by a notice under section 142(1) of the Act to the amalgamating company. MSIL participated in the assessment proceedings of erstwhile amalgamating entity i.e. SPIL through its authorized representative and officers. The assessment was framed. Thereafter during the appellate proceedings before the Tribunal the assessee took an objection that final assessment order was passed

TRISHUL BUILDTECH INFRASTRUCTURE (P) LTD.,,BANGALORE vs. JCIT, BANGALORE

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

2) on 26.9.2013 followed by a notice under section 142(1) of the Act to the amalgamating company. MSIL participated in the assessment proceedings of erstwhile amalgamating entity i.e. SPIL through its authorized representative and officers. The assessment was framed. Thereafter during the appellate proceedings before the Tribunal the assessee took an objection that final assessment order was passed

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S TRISHUL DEVELOPERS, BANGALORE

In the result, appeals filed by the Revenue are dismissed

pricing addition of Rs.78.97\ncrores;\n(ii) Secondly, under the approved scheme of amalgamation, the transferee\nhas assumed the liabilities of the transferor company, including tax\nliabilities;\n(iii) Thirdly, the consequence of the scheme of amalgamation approved\nunder Section 394 of the Companies Act 1956 is that the amalgamating\ncompany ceased to exist. In Saraswati Industrial Syndicate Ltd., (supra

VINOD KUMAR SINGHAL ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, BENGALURU

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

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan Kassessment Year : 2014-15

142 is enquiry before assessment, 143 deals the assessment, 147 is income escaping assessment and 148 is issue of notice where income has escaped assessment as per the Act. In case of income escaping assessment the notice under section 143(2) of the Act can be issued by AO only if there is valid return filed by the assessee under