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)

Price under section 92CA of the Act on 30.03.2022. Several notices were issued under section 142(1) of the Act to the Assessee, which have been duly responded to. 3.7 The TPO passed the order under section 92CA(3) on 29.01.2023, proposing an adjustment of Rs. 348,78,65,338 as follows: Nature of Sl. proposed TP Description Amount

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

144-C does not envisage or contemplate the interdiction or involvement of the transfer pricing officer once a directive has been framed by the Dispute Resolution Panel. The role of the transfer pricing officer comes to an end once an order as contemplated under Section

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

section 234B and 234C of the Act. Each of the above grounds is independent and without prejudice to the other grounds of appeal preferred by the Appellant. The Appellant prays for leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time of hearing, of the appeal

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

transfer pricing purposes. The nature of the item remains unchanged merely due to its presentation in financial statements. 13.2 The assessee further submits that the Learned TPO has not provided any cogent reasoning or justification for excluding such employee-related costs from operating expenses/ income. In the absence of any abnormality or extraordinary event, the remeasurement of defined benefit plans

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

144 ITD\n461) (Hyd) dealt with an issue as to whether mere execution of a\nJDA without commencement of construction be held as transfer as\nper Section 2(47)(v) of the IT Act. The Assessee had entered into a\nJDA with a developer on 28 February 2006. During the relevant\nyear, the developer had not started the construction

WIPRO GE HEALTHCARE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.291/Bang/2022 Assessment Year: 2017-18

section 37 of the I T Act. 16. The Learned AO erred in not giving TDS credit amounting to Rs.1,37,88,075/- and no reasons or explanations have been given for denying the credit. ISSUE OF INTEREST U/S 234A, B& C 17. The appellant denies the liabilities for interest u/s 234A, B& C of the Act. Further prays that

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

Transfer Pricing Officer' was brought into existence by the Finance Act, 2002 w.e.f. 1.6.2002. Under this provision, the onus of computing ALP of the international transactions in certain cases was shifted to the TPO, who was supposed to pass his order under sub-section (3). There was no separate time limit for passing of the order

NETRADYNE TECHNOLOGY INDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD-5(1)(1), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

144 C (1) of the Act dated 10.11.2023 made by the ld. Transfer pricing officer [ the ld. TPO] per Transfer pricing order u/s. 92CA(3) of the Act proposing the above adjustment and pursuant to the direction of the ld. Dispute Resolution Panel-II, Bangalore [ld. DRP] dated 28.8.2024, the above adjustment was retained. Thus, assessee is aggrieved with

M/S EMERSON AUTOMATION SOLUTIONS INTELLIGENT PLATFORMS PVT. LTD,,BANGALORE vs. DCIT, C-3(1)(2), BANGALORE

In the result, the Ground Nos

Bench: Shri Prakash Chand Yadav & Shri Waseem Ahmedm/S Emersion Automation Solutios The Deputy Commissioner Intelligent Platforms Private Limited Of Income Tax, Circle- (Formerly M/S Ge Intelligent 3(1)(2), Bmtc Building, Platforms Private Limited), Velankani Vs. Koramangala, Bangalore Tech Park, Building 9, First Floor, 43 Hosur Road, Bangalore-560100 Pan – Aaacg7573K (Appellant) (Respondent) Assessee By: Sri. Sachit Jolly & Sri. Rishabh Malhotra, Advocates Revenue By: Sri. Subramanian. S, Jcit Date Of Hearing: 13.08.2024 Date Of Pronouncement: 30.08.2024 O R D E R Per: Prakash Chand Yadav,J.M. Present Appeal Of The Assessee Is Arising From The Order Of Ld. Ao / Drp Dated 30Th October, 2018. The Assessee Has Raised 19 Grounds Of Appeal Out Of Which Ground Nos. 1 To 5 Are General In Nature & Hence Not Required Specific Adjudication. Ground No. 6 Related To The Grievance Of The Assessee With Respect To The Adjustment Of Custom Duty, Base Cost, Working Capital Not Granted By The Ao While Completing The Assessment. Ground No. 7 Is With Respect To The Applicability Of Tnmm Method Instead Of Rpm Method Applied By The Assessee For Its Trading Segment Transactions. Ground Nos. 8, 9 & 10 Are Related To The Rejection Of Comparability Analysis Conducted By The Tpo As Affirmed By The Drp & Followed By Ao. Ground No. 11 Is With Respect To The Adjustment Of Working Capital Denied By Tpo Affirmed By Drp & Followed By Ao. Ground No. 12 Is With Respect To The Disallowance Of Foreign Exchange Fluctuation & Ground Nos. 13 & 14 Is With Respect To The Payments Made To Headquarters In Lieu Of Services Obtained By Applying

144 of the Income Tax Act was issued and served on the assessee company. Since there was con-compliance to the 142(1) notice and the explanation given was unacceptable, a Penalty Order u/s271(1)(b) of the Income Tax Act, 1961 dated 15.12.2017 was passed levying penalty of ₹10,000. Later on Mr. NishantPeriwar and Mr.Gurwinder Singh, Authorized Representatives

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144 of the Act is not in accordance with law. The basic details of the returns filed by the appellant for these 2 assessment years are as under: Assessment Date of filing Processing of Notice u/s. Date of filing Assessee Year the return return u/s. 153A return in response to 143[1] 153A Notice Reddy 2010-11 30/11/2011 20/12/2011 17/11/2015

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144 of the Act is not in accordance with law. The basic details of the returns filed by the appellant for these 2 assessment years are as under: Assessment Date of filing Processing of Notice u/s. Date of filing Assessee Year the return return u/s. 153A return in response to 143[1] 153A Notice Reddy 2010-11 30/11/2011 20/12/2011 17/11/2015

SMT. REDDY SANGEETHA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144 of the Act is not in accordance with law. The basic details of the returns filed by the appellant for these 2 assessment years are as under: Assessment Date of filing Processing of Notice u/s. Date of filing Assessee Year the return return u/s. 153A return in response to 143[1] 153A Notice Reddy 2010-11 30/11/2011 20/12/2011 17/11/2015

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144 of the Act is not in accordance with law. The basic details of the returns filed by the appellant for these 2 assessment years are as under: Assessment Date of filing Processing of Notice u/s. Date of filing Assessee Year the return return u/s. 153A return in response to 143[1] 153A Notice Reddy 2010-11 30/11/2011 20/12/2011 17/11/2015

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

144 of the Act is not in accordance with law. The basic details of the returns filed by the appellant for these 2 assessment years are as under: Assessment Date of filing Processing of Notice u/s. Date of filing Assessee Year the return return u/s. 153A return in response to 143[1] 153A Notice Reddy 2010-11 30/11/2011 20/12/2011 17/11/2015

VAZHOOR SUDARSANAN THAMPI,THRISSUR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), WARD-2(1), BENGALURU

Appeal is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan Ka. Y. 2015-16 Appellant Respondent Vazhoor Sudarshanan The Income Tax Officer Thampi International Taxation Vazhoor House, Ward 2 (1) T C 5/1892Valappad Bangalore Vallapad Beach Thrissur Kerala 680567 Pan Afxpt6193D For Appellant Shri Sidhesh N Gadi, Ca For Respondent Dr. Divya K J Cit Dr Date Of Hearing 19-08-2025 Date Of Pronouncement 28-08-2025

144 of the act on 12/12/2024 determining the total income of the assessee at Rs 2,20,00,000/. 10. Aggrieved with the assessment order, assessee is in appeal raising grounds stated here in above. 11. The first ground of appeal is with respect to the issue of notice under section 148 of the act by the jurisdictional assessing officer

M/S. TECHNICOLOR INDIA PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2010-11

144(13) dated 02.01.2015 on the Appeal under section 253(1) of the Income Tax Act, 1961 (the Act") against the order dated January 02, 2015 (received on February 17, 2015) passed under section 143(3) read with section 144C(13) of the Act passed by the Deputy Commissioner of Income Tax, Circle 25(1) and Page

ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing analysis, the purpose is not to compare profit of the tested party with that of the comparables but the purpose is to compare the prices charged by the tested, party with the prices charged by the comparables although when TNMM is adopted as MA.M, the process of such price comparison is by comparing profits of tested party with

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. SRI. SURESH S KANAJI, BENGALURU

In the result, appeal of the revenue is hereby dismissed

144 of the Income Tax Act. However, such\nassessments must be grounded in reasonableness and fairness, relying\non relevant facts and evidence. Arbitrarily adopting a profit rate of 10%\nwithout considering industry norms, past trends, or specific\ncircumstances of the case contravenes these principles. The learned\nCIT(A) rightly observed that the AO's estimation was made in a high