M/S TIMKEN ENGINEERING & RESEARCH INDIA P. LTD. vs. DCIT,

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

transfer pricing issues and regarding revenue’s appeal, it is submitted that ground nos. 4 to 11 in revenue’s appeal are regarding TP issue and since TP issue has attained finality as per MAP resolution, the TP grounds as per revenue’s appeal are also to be rejected. Accordingly these grounds are rejected. 16. Regarding ground

DCIT, BANGALORE vs. M/S TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

transfer pricing issues and regarding revenue’s appeal, it is submitted that ground nos. 4 to 11 in revenue’s appeal are regarding TP issue and since TP issue has attained finality as per MAP resolution, the TP grounds as per revenue’s appeal are also to be rejected. Accordingly these grounds are rejected. 16. Regarding ground

M/S. TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

transfer pricing issues and regarding revenue’s appeal, it is submitted that ground nos. 4 to 11 in revenue’s appeal are regarding TP issue and since TP issue has attained finality as per MAP resolution, the TP grounds as per revenue’s appeal are also to be rejected. Accordingly these grounds are rejected. 16. Regarding ground

TIMKEN ENGINEERING & RESEARCH INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

transfer pricing issues and regarding revenue’s appeal, it is submitted that ground nos. 4 to 11 in revenue’s appeal are regarding TP issue and since TP issue has attained finality as per MAP resolution, the TP grounds as per revenue’s appeal are also to be rejected. Accordingly these grounds are rejected. 16. Regarding ground

M/S TIMES VPL LTD. vs. ADDL.C.I.T.,

In the result, the assessee's appeal for both assessment years 2008-09 and 2009-10 are partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Jason P. Boaz

price of the advertisement space has been debited in the books of account of the assessee as expenditure. However, no tax deducted at sources (TDS) had been made on the payment to BCCL towards the purchase of advertisement space, through the above agreement. ITA Nos.1193 & 1194/Bang/2013 5 5.2 In the course of assessment proceedings, the Assessing Officer examined the Agreement

M/S SALESFORCE.COM INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

Accordingly these ground raised by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.3286/Bang/2018 Assessment Year : 2014-15

Transfer Pricing Related 4. Disallowance under section 40(a)(ia) of the Act 4.1. That on the facts and circumstances of the case, the Learned AO and the Learned Panel erred in holding that tax had not been deducted at source on expenditure amounting to INR 24,586,946 under section 194-I of the Act and disallowing the same

BROADCOM INDIA RESEARCH PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Abraham P. George

transfer prices in relation to the transactions being compared.” 19. A reading of the provisions of Rule 10B(2) of the Rules shows that uncontrolled transaction has to be compared with international transaction having regard to the factors set out therein. Before us there is no dispute that the TNMM is the most appropriate method for determining

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

INCOME TAX OFFICER (TDS),, BANGALORE vs. M/S. ITC EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD, BANGALORE

In the result, all the appeals filed by the revenue are dismissed and all the COs filed by the assessee are also dismissed

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

price and the Respondent Society has agreed to purchase such sites and paid certain sum (Clause 2 the Agreement ) in pursuance of the agreement . All these arrangements in the impugned MOU, read as a whole, confirm the privileges of ownership on Respondent Society without transfer of title, which could fall under section 2 (47) (v) as held

DASA SHETTY KANTHA,BANGALORE vs. ACIT CIRCLE 6(3)(1), BANGALORE, BANGALORE

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

194C of the Act. The learned AR contended that the\nview taken by AO that improvement of kitchen cabinet or interior work\nwas not mentioned in the sale deed, therefore the same is not allowable\nis unjustified and flawed for the reasoned there is no legal requirement\nfor showing such interior work in the sale deed. It is part

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

price at 25.25%. Even though, DRP refused to interfere with the objections of the assessee in its order, we were informed that DRP has directed the TPO/A.O. not to make any negative working capital adjustment in some of the cases in the next assessment year, in the cases of Market Tools Research P. Ltd., and Mega Systems Worldwide India

DASA SHETTY KANTHA,BANGALORE vs. ACIT CIRCLE 3(2)(1), BANGALORE, BANGALORE

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

194C of the Act. The learned AR contended that the\nview taken by AO that improvement of kitchen cabinet or interior work\nwas not mentioned in the sale deed, therefore the same is not allowable\nis unjustified and flawed for the reasoned there is no legal requirement\nfor showing such interior work in the sale deed. It is part