M/S SAP LABS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE
In the result appeal filed by the assessee stands partly allowed and appeal filed by the revenue stands dismissed
ITA 561/BANG/2015[2010-11]Status: DisposedITAT Bangalore28 Jul 2022AY 2010-11
Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 561/Bang/2015 Assessment Year : 2010-11 M/S. Sap Labs India Pvt. Ltd., The Deputy No. 138, Export Promotion Commissioner Of Industrial Park, Income Tax, Whitefield, Circle – 6 (1)(1), Bangalore – 560 066. Bangalore. Vs. Pan: Aafcs3649P Appellant Respondent & It(Tp)A No. 437/Bang/2015 (By Revenue) : Shri Aliasgar Rampurawala, Assessee By Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 20-06-2022 Date Of Pronouncement : 28-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee As Well As Revenue Against Final Assessment Order Dated 29.01.2015 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For Assessment Year 2010-11 On Following Consolidated Grounds Of Appeal. Assessee’S Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another.
For Respondent: Shri Arun Kumar, CIT DR
Section 92D
transfer pricing adjustment,
22. Addition made by the Ld.AO in respect of Corporate tax issues are alleged by the assessee in Ground no.7-10 and are adjudicated as under.
23. Ground no.7-8 is in respect of disallowance of deduction under section 80
JJAA of the Act, amounting to Rs.13,07,42,470/-.
24. Ground Nos.9-10 is in respect of disallowance under
