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

section 92CA of the act.\nAt this juncture, we emphasize that the moment a reference is made by the Ld.AO to the transfer pricing officer u/s. 92CA(1),\nPage 15 of 86\nIT(TP)A Nos. 303 & 839/Bang/2022\nthe time period to pass an assessment order u/s. 143

SAP INDIA PRIVATE LIMITED,BANGALORE vs. JURISDICTIONAL ASSESSING OFFICER - DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), BANGALORE

The appeal of the assessee is allowed to the extent indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

143 (3) read with section 144C (13) read with section 144B of the income tax act, 1961 (the Act) passed by the assessment unit, income tax department on 18 June 2024 pursuant to the order dated 28 July 2023 passed by the Deputy Commissioner of income tax (transfer pricing

DY.COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2),, AHMEDABAD vs. M/S.QUINTILES RESEARCH INDIA PVT.LTD.,, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the departmental appeal is dismissed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2011-12

Transfer Pricing Officer did not pass the order under sub- section (3) of section 92CA before the said date. [Clauses 25,39 and 40]" (emphasis supplied) 4. Two points clearly stand out from the above excerpt showing the legislative intent for the proposed amendment: First is that the TPO shall determine the Arm's Length Price at least 2 months

DECATHLON SPORTS INDIA PRIVATE LIMITED,BANGALORE , KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 2(2)(1), BENGALURU, KARNATAKA

In the result appeal of the assessee is partly allowed as indicated\nabove

sections": [ "143(3)", "144B", "92CA(3)", "37(1)", "234B", "270A" ], "issues": "Whether the transfer pricing adjustments for the trading segment

QUINTILES RESEARCH (INDIA) PVT. LTD.,BANGALORE vs. THE DY.CIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the\ndepartmental appeal is dismissed

Transfer Pricing adjustment was quashed.", "result": "Partly Allowed", "sections": [ "143(3)", "144C", "153", "153B", "92CA", "92CA(3)", "92CA(3A)", "92C" ], "issues

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing (“TP) order dated 30.10.2019 under section 92CA of the Act and has made the following adjustments: S Particulars Amount (Rs) No A International Transaction with Associated Enterprises (“AE”) 1. Management Fee 6,00,00,000 2. Payment of Royalty 2,55,70,901 B Specified Domestic Transaction 1. Sales promotion expenses paid to United

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing (“TP) order dated 30.10.2019 under section 92CA of the Act and has made the following adjustments: S Particulars Amount (Rs) No A International Transaction with Associated Enterprises (“AE”) 1. Management Fee 6,00,00,000 2. Payment of Royalty 2,55,70,901 B Specified Domestic Transaction 1. Sales promotion expenses paid to United

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Pricing Addition in respect of interest on External Commercial Borrowings (ECB) and interest on delayed receivable amounting to INR.75,39,13,371/- and INR.29,837/-, respectively. 4. The Assessing Officer passed a Draft Assessment Order, dated 20/12/2023, under the provisions of section 143(3) read with section 144C read with section 144B of the Act incorporating the aggregate Transfer

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)

143(2) was issued even after the delay in filing of return was condoned. 3.6 A reference was made to the Deputy Commissioner of Income-tax - Transfer Pricing ('TP') - 2(1)(2), Bengaluru ("Transfer Pricing Office / TPO") for determination of Arm's Length Price under section

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

Transfer Pricing Officer passed order under Section 92CA of IT Act on 30.01.2015 for the assessment year 2011-12. Subsequently, the respondent-Revenue passed draft assessment order under Section 144C read with Section 143

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

143(3) read\nwith section 144C(13) of the Income-tax Act 1961 ('the Act') in\npursuance of the directions issued by Dispute Resolution Panel\n(hereinafter referred to as the \"Hon'ble DRP\"), Bengaluru dated 09\nSeptember 2019 under section 144C(5) of the Act inter-alia on the\nfollowing grounds which are without prejudice to each other.\nThat

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

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

143 (2) was issued on 29 June 2021, the assessee was also found to have entered into international transactions with its associated enterprises [AE]. Therefore the reference was made to the learned Transfer Pricing Officer [TPO] - ACIT, TP 1(1)(1), Bangalore (the ld. TPO) for determination of the arm's-length price [ALP]. The assessee has entered into

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

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

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

Section 143(2) of the Act was issued on 28.08.2015. During the course of assessment proceedings the assessee’s case was referred to Transfer Pricing

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.

Section 143(2) of the Act was issued on 28.08.2015. During the course of assessment proceedings the assessee’s case was referred to Transfer Pricing

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

143(3) r.w.s. 144C(15) of the Income-tax Act,1961 ['the Act' for short] dated 21.10.2019. 2. Facts of the case are that the learned Transfer Pricing Officer (“TPO”) has passed the transfer pricing (“TP) order dated 17.10.2018 under section

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

143(3) read with Section 144C(13) of the Income Tax Act, 1961. 2. In the present case the TPO had proposed an adjustment of Rs.31,26,65,872/on account of arm's length price vide its order dated 21 .10.2016, out of which the adjustment of Rs.25,23,76,5211- was made in the trading segment, and the adjustment

EBIX TRAVELS PVT. LTD.,NEW DELHI vs. DCIT,CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result appeal of the assessee is partly allowed

section 143(2) was\nserved to the assessee on 28 June 2022.\n7. The assessee entered an international transaction.\nConsequently, a reference was made to the Transfer Pricing

MCAFEE SOFTWARE INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri George George K & Shri Waseem Ahmed

143(1) of the Act was not incorporated. In the draft assessment order, the A.O. had incorporated the T.P. adjustment IT(TP)A No.110/Bang/2024 Page 3 of 9 proposed by the Transfer Pricing Officer (TPO) and disallowance u/s 40(a)(ia) of the Act. 5. The assessee, being aggrieved by the DAO, filed objections before the Dispute Resolution Panel