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

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)

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

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

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

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

WEG INDUSTRIES (INDIA) PRIVATE LIMITED,BENGALURU vs. ASSESSING OFFICER, BMTC BUILDING

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

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

144B of the Act, is barred by limitation under section 153 of the Act, and is thus void-ab-initio, illegal and bad in law and liable to be quashed. MANUFACTURING SEGMENT 3. On the facts and circumstances of the case and in law, the Ld. Transfer Pricing

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

In the result appeal filed by the assessee is partly allowed

144B of The Income - Tax Act, 1961 (the Act) passed by the\nassessment unit, income tax Department on 24 July 2023 pursuant to the\ntransfer pricing assessment order under Section 92CA (3) passed by The\nDeputy Commissioner Of Income Tax (Transfer

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 422/Bang/2022 Assessment Year : 2017-18 M/S. Aptean India Pvt. Ltd., 1/2, 8Th Floor, Level 5, The Assistant Golden Heights, Commissioner Of 59Th C Cross Road, Income Tax, 4Th M Block, Circle – 1(1)(1), Rajajinagar, Vs. Bangalore. Bangalore – 560 010. Pan: Aaacc5890M Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Shri Praveen Karanth, Cit- Revenue By Dr Date Of Hearing : 03-11-2022 Date Of Pronouncement : 20-01-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 25/03/2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another General Ground 1. On The Facts & In The Circumstances Of The Case & In Law, Final Assessment Order Passed By National Faceless

section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, in pursuance to the order of the Deputy Commissioner of Income Tax,1(1)(1) ('the learned Transfer Pricing

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

In the result the appeal filed by the assessee is allowed

144B of the Act dated 02/09/2022 is found to be erroneous in\nso far as it is prejudicial to the interest of revenue within the\nmeaning of section 263 of the Act, as such the AO has failed to\nexamine and verify the above issue and failed to tax the income\nfrom other sources. Thus, we are of the considered

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

In the result the appeal filed by the assessee is allowed

144B of the Act dated 02/09/2022 is found to be\nerroneous in so far as it is prejudicial to the interest of revenue within the meaning\nof section 263 of the Act, as such the AO has failed to examine and verify the above\nissue and failed to tax the income from other sources. Thus, we are of the considered

ASTRAZENECA PHARMA INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.

144B of the Act dated 30.4.2021. The assessee has raised following grounds of appeal: GENERAL 1. On the facts and circumstances of the case and in law the learned AO based on the directions of DRP has assessed the total income of the Appellant at INR 42,23,86,980 as against returned income/ (loss