DCIT, BANGALORE vs. M/S RANDOX LABORATORIES INDIA PVT. LTD.,, MUMBAI

In the result, appeal by the Assessee is partly allowed and the appeal by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

section (1), be deemed to be a transaction entered into between two associated enterprises, if there exists a prior agreement in relation to the relevant transaction between such other person and the associated enterprise, or the terms of the relevant transaction are determined in substance between such other person and the associated enterprise. Explanation.—For the removal of doubts

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

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing adjustment made by the TPO with respect to payment of royalty @ 1%. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 40 of 62 10. The ld.AR submitted that this issue is covered in assessee’s own case in ITA No.506/Bang/2016 vide order dated 6/12/2021 for the asst. year 2011-12 wherein

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

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing adjustment made by the TPO with respect to payment of royalty @ 1%. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 40 of 62 10. The ld.AR submitted that this issue is covered in assessee’s own case in ITA No.506/Bang/2016 vide order dated 6/12/2021 for the asst. year 2011-12 wherein

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

priced on a time and material basis are\nrecognized when services are rendered and related costs are incurred.\nRevenues from time bound fixed price contracts, are recognized over the\nlife of the contract using the proportionate of completion method, with\ncontract costs determining the degree of completion. Foreseeable losses\non such contracts are recognized when probable.\nRevenues from maintenance contracts

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 92CD of the act, and completion of Transfer pricing proceedings accepting the modified tax returns. Accordingly, the transfer pricing issues for all the years under consideration and the relevant grounds as tabulated hereinabove in assessee’s appeals are allowed to be withdrawn. Accordingly, all the grounds related to transfer pricing issues in assessee’s appeals are dismissed as withdrawn

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

LENOVO (INDIA) PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD- 4(1)(1), BANGALORE

In the result, the appeal of the assessee is partly allowed for above terms

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

transfer pricing (“TP”) adjustment of INR 4,27,47,621 to the returned income of the Appellant and in holding that the international transactions undertaken by the Appellant with its associated enterprises (“AEs”) in the manufacturing segment were not at arm’s length. Rejection of Internal Comparable Uncontrolled Price Method adopted as the most appropriate method by the Appellant

BIOCON LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal filed by assessee for assessment year

Bench: Shri B.R. Baskaran & Smt Beena Pillai

Transfer Pricing ("TP") documentation which has been prepared by the Appellant in the manner as contemplated under the relevant provisions of the Act and the Income-tax Rules,1962 ("the Rules"). 4.11 The learned AO/TPO has erred in law and on facts in using the information sought from CRISIL under section 133(6) of the Act, since such information from

JCIT, BANGALORE vs. M/S BIOCON LTD.,, BANGALORE

In the result appeal filed by assessee for assessment year

Bench: Shri B.R. Baskaran & Smt Beena Pillai

Transfer Pricing ("TP") documentation which has been prepared by the Appellant in the manner as contemplated under the relevant provisions of the Act and the Income-tax Rules,1962 ("the Rules"). 4.11 The learned AO/TPO has erred in law and on facts in using the information sought from CRISIL under section 133(6) of the Act, since such information from