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1,787 results for “transfer pricing”+ Section 15clear

Sorted by relevance

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Key Topics

Section 143(3)66Addition to Income51Section 153A45Transfer Pricing42Comparables/TP41Section 92C24Disallowance22Section 14820Deduction

SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

ITA 1481/BANG/2010[2006-07]Status: DisposedITAT Bangalore31 Mar 2016AY 2006-07

Bench: Shri. Abraham P. George

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. G. R. Reddy, CIT – DR -I
Section 144C(5)

Pricing of the international transactions to the TPO, he was of the opinion that aggregation of transactions was permissible only if there were closely linked transactions which could not be separately analysed. As per the TPO assessee had two segments namely manufacturing and trading and even these were aggregated for the TNMM study. TPO also relied on OECD guidelines

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

ITA 84/BANG/2015[2010-11]Status: DisposedITAT Bangalore

Showing 1–20 of 1,787 · Page 1 of 90

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20
Section 14719
Section 10A19
Section 36(1)(viia)14
25 Jul 2019
AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

15% upon issue of Compulsory Convertible Debenture to its three respective associated enterprises namely, Flight Training Mauritius, Emirates Dubai and CAE Hungary. These three international transactions, in respect of such interests paid, were referred by the Assessing Officer to the Transfer Pricing Officer for mere determination of their respective arm's length prices within the ITA No. 2006/Bang/2017

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

ITA 63/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

15% upon issue of Compulsory Convertible Debenture to its three respective associated enterprises namely, Flight Training Mauritius, Emirates Dubai and CAE Hungary. These three international transactions, in respect of such interests paid, were referred by the Assessing Officer to the Transfer Pricing Officer for mere determination of their respective arm's length prices within the ITA No. 2006/Bang/2017

SHRI. KOLA VENKAT RAMA NAIDU,BANGALORE vs. THE COMMISSIONER OF INCOME TAX (APPEALS) - 6, BANGALORE

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

ITA 206/BANG/2020[2010-11]Status: DisposedITAT Bangalore05 Aug 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 133ASection 2(47)(v)Section 250

price absolutely without any basis and had arrived at an imaginary figure without any basis and therefore the impugned orders is liable to be set aside on this ground also. (7) The learned respondent also seriously erred in not considering the various statutory documents like granting of Khata on the property, releasing the original Joint Development Agreement by the Registering

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2086/BANG/2018[2010-11]Status: DisposedITAT Bangalore16 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2088/BANG/2018[2012-13]Status: DisposedITAT Bangalore16 Jun 2022AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 948/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 947/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2087/BANG/2018[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2089/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 1962/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

transfer is shown at a lesser figure than that actually received. 3.14 Hence, it is submitted that the 1st proviso to section 2 (15) can be invoked only if, under the specific facts and circumstances, the case falls within the mischief as envisaged by the Legislature. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra

M/S TYCO ELECTRONICS SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal being IT(TP)A No

ITA 1251/BANG/2011[2007-08]Status: DisposedITAT Bangalore19 Feb 2020AY 2007-08

Bench: Shri N.V.Vasudevan & Shri A.K.Garodia

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Ms.Neera Malhotra, CIT-DR
Section 143(3)

15 26. As far as ground no.7 is concerned, we find that despite elaborate submissions made before the DRP, the DRP has merely observed in page-16 of its order that the AO has dealt with the objections of the assessee. The order of the DRP is a non speaking order not dealing with specific contentions of the Assessee which

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1307/BANG/2010[2004-05]Status: DisposedITAT Bangalore11 Mar 2022AY 2004-05

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

15 are concerned, they are nothing but an elaboration of ground Nos.5.4 and 5.5 already raised by the assessee in the main grounds of appeal. At the time of hearing, learned Counsel for the assessee made 7. submissions on ground Nos.3.1 and 3.2. In these grounds, it has been submitted that the AO, before making a reference to Transfer Pricing

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1308/BANG/2010[2005-06]Status: DisposedITAT Bangalore11 Mar 2022AY 2005-06

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

15 are concerned, they are nothing but an elaboration of ground Nos.5.4 and 5.5 already raised by the assessee in the main grounds of appeal. At the time of hearing, learned Counsel for the assessee made 7. submissions on ground Nos.3.1 and 3.2. In these grounds, it has been submitted that the AO, before making a reference to Transfer Pricing

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1306/BANG/2010[2003-04]Status: DisposedITAT Bangalore11 Mar 2022AY 2003-04

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

15 are concerned, they are nothing but an elaboration of ground Nos.5.4 and 5.5 already raised by the assessee in the main grounds of appeal. At the time of hearing, learned Counsel for the assessee made 7. submissions on ground Nos.3.1 and 3.2. In these grounds, it has been submitted that the AO, before making a reference to Transfer Pricing

M/S. TRANSWORLD ICT SOLUTIONS (P) LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1305/BANG/2010[2002-03]Status: DisposedITAT Bangalore11 Mar 2022AY 2002-03

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92C(2)

15 are concerned, they are nothing but an elaboration of ground Nos.5.4 and 5.5 already raised by the assessee in the main grounds of appeal. At the time of hearing, learned Counsel for the assessee made 7. submissions on ground Nos.3.1 and 3.2. In these grounds, it has been submitted that the AO, before making a reference to Transfer Pricing

DEPUTY COMMISSIONER OF INCOME TAX (E) CIRCLE- 1, BANGALORE vs. M/S BANGALORE DEVELOPEMNT AUTHORITY , BANGALORE

In the result, the assessee’s appeal for Assessment Year 2012-13 is allowed as indicated above and Revenue’s cross appeal is consequently dismissed

ITA 1087/BANG/2017[2012-13]Status: DisposedITAT Bangalore22 Mar 2019AY 2012-13

Bench: Shri Jason P. Boaz & Shri Laliet Kumar

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Ms. Susan D. George, CIT(DR)
Section 11Section 12ASection 143(1)Section 143(3)

transfer of the property. (x) Formation of new extensions or layouts or making new private streets. (xi) Allotment/ sale of sites and buildings by direct sales, lease cum sale method and through auction sales in respect of corner sites and commercial sites. ITA No. 1087/Bang/2017 Page 20 of 42 5.3.5 The AO has summarized the main objects, functions and activities

BANGALORE DEVELOPMENT AUTHORITY ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX EXEMPTIONS RANGE , BANGALORE

In the result, the assessee’s appeal for Assessment Year 2012-13 is allowed as indicated above and Revenue’s cross appeal is consequently dismissed

ITA 1104/BANG/2017[2012-13]Status: DisposedITAT Bangalore22 Mar 2019AY 2012-13

Bench: Shri Jason P. Boaz & Shri Laliet Kumar

For Appellant: Shri. V. Chandrashekhar, AdvocateFor Respondent: Ms. Susan D. George, CIT(DR)
Section 11Section 12ASection 143(1)Section 143(3)

transfer of the property. (x) Formation of new extensions or layouts or making new private streets. (xi) Allotment/ sale of sites and buildings by direct sales, lease cum sale method and through auction sales in respect of corner sites and commercial sites. ITA No. 1087/Bang/2017 Page 20 of 42 5.3.5 The AO has summarized the main objects, functions and activities

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 813/BANG/2019[2014-15]Status: DisposedITAT Bangalore02 Mar 2021AY 2014-15

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

For Appellant: Sri.Padamchand Khincha, CAFor Respondent: Smt.R.Premi, JCIT-DR
Section 191Section 194Section 201Section 201(1)Section 206ASection 4

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

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

In the result, appeal of the assessee is partly allowed

ITA 202/BANG/2021[2015-16]Status: DisposedITAT Bangalore26 Jul 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.202/Bang/2021 Assessment Year :2015-16 M/S. Nike India Pvt.Ltd., Vs. Dcit, Ground & First Floor, Circle – 3(1)(1), Olympia Building, No.66/1, Bagmane Tech Bengaluru. Park, C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aabcn 9612 K Appellant Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Smt. Susan Dolores George, Cit(Osd)(Itat), Bengaluru. Date Of Hearing : 21.07.2022 Date Of Pronouncement : 26.07.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(ITAT), Bengaluru
Section 144(3)Section 92C

15. 20.1 This expenditure was disallowed by way of Transfer pricing adjustment in the earlier years. In the assessment year 2012-13 and 2014-15, the assessing officer has disallowed the expenditure incurred on purchase of samples and incidental expenses holding IT(TP)A No.202/Bang/2021 Page 32 of 38 that this expenditure is to be borne by the manufacturer only