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45 results for “transfer pricing”+ Section 172clear

Sorted by relevance

Mumbai240Delhi131Hyderabad73Chennai66Cochin61Chandigarh59Jaipur48Bangalore45Raipur19Surat14Ahmedabad12Nagpur10Indore10Agra8Kolkata8Varanasi5Lucknow4Rajkot4Cuttack3Jodhpur2Pune2Dehradun1Allahabad1Guwahati1

Key Topics

Section 153A44Section 13238Addition to Income36Section 143(3)23Section 4021Disallowance18Section 132(4)14Section 234A13Section 131

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment

UXC INDIA IT SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

Showing 1–20 of 45 · Page 1 of 3

11
Survey u/s 133A11
Transfer Pricing9
Section 234B7

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

ITA 236/BANG/2021[2016-17]Status: DisposedITAT Bangalore20 Jan 2023AY 2016-17
For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri K. Sankar Ganesh, JCIT-DR
Section 143(3)Section 92C

sections 143(3A) & 143(3B) of the Act, for the subject assessment year at INR 4,76,55,172 as against the returned income of INR 1,97,83,270. 2 IT(TP)A No. 236/Bang/2021 M/s. UXC India IT Services Pvt. Ltd. 2. That on the facts and circumstances of the case and in law, the orders passed

JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R &D INSTITUTE INDIA- BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

ITA 1046/BANG/2019[2013-14]Status: DisposedITAT Bangalore30 May 2024AY 2013-14

Bench: Smt Beena Pillai & Shri Waseem Ahmed

For Appellant: Smt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective grounds for the years under consideration as tabulated hereinabove, in the assessee’s appeal stands withdrawn. The Page 4 ITA/IT(TP)A Nos. 1008, 1092, 1166, 484, 958, 1045, 1046 & 978/Bang/2019 assessee accordingly filed revised grounds of appeal pursuant to the MAP proceedings having culminated. Accordingly, the respective grounds mentioned hereinabove becomes infructuous

JOINT COMMISSIONER OF INCOME-TAX, SPECIAL RANGE-6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA-BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

ITA 958/BANG/2019[2011-12]Status: DisposedITAT Bangalore30 May 2024AY 2011-12

Bench: Smt Beena Pillai & Shri Waseem Ahmed

For Appellant: Smt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective grounds for the years under consideration as tabulated hereinabove, in the assessee’s appeal stands withdrawn. The Page 4 ITA/IT(TP)A Nos. 1008, 1092, 1166, 484, 958, 1045, 1046 & 978/Bang/2019 assessee accordingly filed revised grounds of appeal pursuant to the MAP proceedings having culminated. Accordingly, the respective grounds mentioned hereinabove becomes infructuous

JOINT COMMISSIONER OF INCOME -TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA-BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

ITA 978/BANG/2019[2014-15]Status: DisposedITAT Bangalore30 May 2024AY 2014-15

Bench: Smt Beena Pillai & Shri Waseem Ahmed

For Appellant: Smt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective grounds for the years under consideration as tabulated hereinabove, in the assessee’s appeal stands withdrawn. The Page 4 ITA/IT(TP)A Nos. 1008, 1092, 1166, 484, 958, 1045, 1046 & 978/Bang/2019 assessee accordingly filed revised grounds of appeal pursuant to the MAP proceedings having culminated. Accordingly, the respective grounds mentioned hereinabove becomes infructuous

M/S. SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME- TAX, CIRCLE - 6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

ITA 1166/BANG/2019[2013-14]Status: DisposedITAT Bangalore30 May 2024AY 2013-14

Bench: Smt Beena Pillai & Shri Waseem Ahmed

For Appellant: Smt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective grounds for the years under consideration as tabulated hereinabove, in the assessee’s appeal stands withdrawn. The Page 4 ITA/IT(TP)A Nos. 1008, 1092, 1166, 484, 958, 1045, 1046 & 978/Bang/2019 assessee accordingly filed revised grounds of appeal pursuant to the MAP proceedings having culminated. Accordingly, the respective grounds mentioned hereinabove becomes infructuous

M/S. SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised grounds stands allowed and the appeals filed by the revenue stands dismissed for the years under consideration

ITA 1092/BANG/2019[2012-13]Status: DisposedITAT Bangalore30 May 2024AY 2012-13

Bench: Smt Beena Pillai & Shri Waseem Ahmed

For Appellant: Smt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective grounds for the years under consideration as tabulated hereinabove, in the assessee’s appeal stands withdrawn. The Page 4 ITA/IT(TP)A Nos. 1008, 1092, 1166, 484, 958, 1045, 1046 & 978/Bang/2019 assessee accordingly filed revised grounds of appeal pursuant to the MAP proceedings having culminated. Accordingly, the respective grounds mentioned hereinabove becomes infructuous

M/S SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

ITA 484/BANG/2019[2014-15]Status: DisposedITAT Bangalore30 May 2024AY 2014-15
For Appellant: \nSmt. Tanmayee RajkumarFor Respondent: \nShri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective\ngrounds for the years under consideration as tabulated\nhereinabove, in the assessee's appeal stands withdrawn. The\nassessee accordingly filed revised grounds of appeal pursuant to\nthe MAP proceedings having culminated.\nAccordingly, the respective grounds mentioned hereinabove\nbecomes infructuous in both assessee's as well as departmental\nappeals.\nAccordingly, ground

JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA -BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

ITA 1045/BANG/2019[2012-13]Status: DisposedITAT Bangalore30 May 2024AY 2012-13
For Appellant: \nSmt. Tanmayee RajkumarFor Respondent: Shri D.K. Mishra, CIT-DR
Section 234ASection 234BSection 234CSection 32Section 40

transfer pricing issues contested in the respective\ngrounds for the years under consideration as tabulated\nhereinabove, in the assessee's appeal stands withdrawn. The\nassessee accordingly filed revised grounds of appeal pursuant to\nthe MAP proceedings having culminated.\nAccordingly, the respective grounds mentioned hereinabove\nbecomes infructuous in both assessee's as well as departmental\nappeals.\nAccordingly, ground

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE vs. L JAVERCHAND JEWELLERS PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed

ITA 1542/BANG/2024[2019-20]Status: DisposedITAT Bangalore09 Jan 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20 L. Javerchand Jewellers Pvt. Ltd. No.1, 2Nd Floor & 3Rd Floor, Choksi Chamber Dcit 1Stagyari Lane Vs. Central Circle-1 Zaveri Bazar Mangaluru Mumbai 400 002

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Sri V. Parithivel, D.R
Section 132(4)Section 143(1)Section 143(3)Section 153CSection 250Section 270ASection 274

172/- was levied L. Javerchand Jewellers Pvt. Ltd., Mumbai Page 8 of 17 for mis-reporting of income as per provisions of sec. 270A(1) r.w.s. 270A(9) of the Act due to the suppression of sales and the AO while initiating the penalty in the assessment order clearly mentioned the term mis-reporting of income

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1456/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1451/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2129/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2130/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1444/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1448/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1445/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1457/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1447/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1446/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books