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

MFX INFOTECH PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

Transfer Pricing Officer/ TPO); and Honorable Dispute Resolution Panel [collectively referred as "lower income tax authorities" for brevity] to the extent prejudicial to the assessee are bad in law and liable to be quashed. 2. The learned AO erred in not passing the order in conformity with the procedure prescribed in faceless assessment scheme under section 144B

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

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

MATCHMOVE INDIA PRIVATE LIMITED,BANGALORE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND INCOME TAX OFFICER, WARD 4(1)(3), BANGALORE, BANGALORE

In the result, ground no. 4 of the Appeal is allowed with above direction

Bench: Shri Prashant Maharishi & Shri Sounadararajan K.Ittpa No. 2255/Bang/2024 Assessment Year : 2021-22

144B of the Income Tax Act, 1961 (the Act) by the Assessment Unit, Income Tax Department (the Ld. Assessing Officer/ AO] pursuant to the direction of the Ld. Dispute Resolution Panel [ the ld. DRP] raising following grounds of Appeal:- Based on the facts and circumstances of the case and in law, the Appellant respectfully craves leave to prefer an appeal

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

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

Transfer 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

SOFTLAYER TECHNOLOGIES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(2), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

144B of the Income- tax Act dated 24/04/2021 for the assessment year 2016-17 on the various grounds of appeal and thereafter it filed two times IT(TP)A No.265/Bang/2021 Page 2 of 66 additional grounds of appeal and later on it filed concise grounds of appeal. Theconsie grounds of appal is as under:- “General Grounds 1. The orders passed

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, grounds 20 to 23 are allowed for statistical purposes

transfer pricing order dated 30.10.2019 determining the total TP adjustment of Rs.3,48,49,941 in respect of software development services transaction of the assessee and a sum of Rs.83,55,708 in respect of interest on delayed receipt of trade receivables from its AEs. Pursuant to the TPO’s order, a draft assessment order dated 31.12.2019 was passed

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

144B on 01.03.2022 for A.Y. 2017-18 and 28.07.2022 for A.Y. 2018-19.\nPage 2 of 86\nIT(TP)A Nos. 303 & 839/Bang/2022\n2. The Ld.AR submitted that the brief facts leading to the transfer pricing adjustment as well as the corporate tax additions are identical for both the years under consideration. At the outset, he submitted that assessee

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

144B of the Income Tax Act, 1961 (The Act) on 29 July 2024 passed by the Assessment Unit, Income Tax Department (the ld. AO) wherein total income shown as per return of income filed of ₹ Page 2 of 29 444,408,150/– computed u/s. 143(1)(a) at ₹ 563,943,540/– was further added by the variations proposed with respect

KOCH BUSINESS SOLUTIONS INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Transfer Pricing Officers tend to take a conservative view. The correction of such view take very long time with the existing appellate structure. With a view to provide speedy disposal, it is proposed to amend the Income-tax Act so as to create an alternative dispute resolution mechanism within the income-tax department and accordingly, section 144C has been proposed

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 Officers tend to take a conservative view. The correction of such view take very long time with the existing appellate structure. With a view to provide speedy disposal, it is proposed to amend the Income-tax Act so as to create an alternative dispute resolution mechanism within the income-tax department and accordingly, section 144C has been proposed

M/S. IG INFOTECH (INDIA) PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 144B of the Income Tax Act, 1961 ("the Act") after considering the adjustments proposed by the learned Transfer Pricing

M/S. TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BANGALORE

In the result, all these appeals are partly allowed

Bench: Shri N. V. Vasudevan & Shri.Chandra Poojariit(Tp)A Nos. & Appellant Respondent Assessment Year 2593/Bang/2019 M/S. Te Connectivity India Private Limited, Acit, 2015-16 Te Park, 22B, Doddenakundi Corporation, Circle – 2, 2Nd Phase, Industrial Area, Large Taxpayer Unit, Whitefield Road, Bengaluru Bengaluru – 560 048. Pan: Aabct 7374 C 372/Bang/2021 -Do- -Do- 2016-17 200/Bang/2022 -Do- Dcit, Ltu, 2017-18 Circle – 2, Bengaluru. 716/Bang/2022 -Do- Acit, 2018-19 Circle – 7(1)(1), Bengaluru. Assessee By : Shri Sriram Seshadri, Advocate Revenue By : Shri Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 21.09.2022 Date Of Pronouncement : 23.09.2022 O R D E R Per N. V. Vasudevan:

144B of the Act. iv.Assessment Year 2018-19 – Final Order of Assessment dated 30.06.2022 passed by ACIT, Circle – 7(1)(1), Bengaluru, under section 143(3) r.w.s. 144C(13) of the Act. 2. Since common issues arise for consideration in all these appeals, they were heard together and we deem it convenient to pass consolidated order. 3. The factual background

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

144B of the Income-tax Act,1961 ['the Act' for short] for assessment year 2016-17 in pursuance of directions given by Ld Dispute Resolution Panel (DRP) dated 29.03.2021. IT(TP)A No.370/Bang/2021 Page 2 of 110 2. The brief facts of the case are that the assessee filed his return of income on 30.11.2016 declaring at income

KENNAMETAL INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubey

144B of the Income Tax Act, 1961 (in short “The Act”). The assessee has raised following grounds of appeal: “Assessment Order passed by the learned Assessing Officer is bad in law 1.1. The Appellant submits that the order of the Assessing Officer ("AO") is bad in law and facts on account of the grounds raised as below. 2. Transfer Pricing

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

In the result appeal of the assessee is partly allowed

144B of the act is otherwise without jurisdiction\ntherefore deserves to be quashed as such.\nvii. That the learned assessing officer has further erred both\nin law and on facts in levying interest under section\n234A of the act and interest under section 234B of the\nact which are not levy of on the facts and circumstances\nof the case

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

144B of the Act by the AO dated 21.07.2022 with the following grounds of appeal:- “1. That the order of the Learned Deputy Commissioner of Income-tax, Circle - 3(1)(1) ("Assessing Officer" or "Learned AO"), which is in conformity with the directions of the Dispute Resolution Panel - II, Bangalore ("DRP", "Learned Panel") and the order of the Learned Deputy