INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

1)(a) which stood at two years from the end of the assessment year. Section 92CA with the caption 'Reference to the Transfer Pricing Officer' was brought into existence by the Finance Act, 2002 w.e.f. 1.6.2002. Under this provision, the onus of computing ALP of the international transactions in certain cases was shifted to the TPO, who was supposed

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

2) exceeds the value adopted or assessed or assessable by the stamp valuation authority referred to in sub-section (1), the value so adopted or assessed or assessable by such authority shall be taken as the full value of the consideration received or accruing as a result of the transfer. 31. General background of Section 50C a) Generally

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

2\ndifferent business transferred agreement (BTA) with its holding company\nInfosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the\nF.Y. 2014-15 for transfer of Edge suit of product division for a\nconsideration of Rs. 421 crores. The second BTA was entered as on 17th\nApril 2015 i.e. during

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

1)(a) of the Act confirming power to commissioner/joint commissioner of appeal in respect of setting aside the assessment and refer back the case to the AO for fresh assessment, but such power can only be exercised when the assessment made under section 144B of the Act. 18.5 In the present case, the assessment year involved

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

1)(a) of the Act confirming power to commissioner/joint commissioner of appeal in respect of setting aside the assessment and refer back the case to the AO for fresh assessment, but such power can only be exercised when the assessment made under section 144B of the Act. 18.5 In the present case, the assessment year involved

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan K

1)(a) of the Act confirming power to commissioner/joint commissioner of appeal in respect of setting aside the assessment and refer back the case to the AO for fresh assessment, but such power can only be exercised when the assessment made under section 144B of the Act. 18.5 In the present case, the assessment year involved

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, HUBBALLI vs. SMT. SHEELA PRASANNAKUMAR , CHITRADURGA

In the result, the appeals of the Revenue are dismissed

transfer of shares by the assessee and others on 18.01.2017 at\na purchase price of Rs.28 Crores and immediately they have paid Rs.3\nCrores by cheque towards advance consideration as under:\ni. Rs 1,00,00,000/- (Rupees One Crore only) paid vide Cheque\nbearing No 149250 Dated 18-01-2017 drawn on Axis Bank.\nChitradurga, to the First Seller

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

transfer the land\nto the Board for the purpose for which the land has been acquired.\"\n28. Section 29 deals with payment of compensation, which is extracted as\nunder:\n“29. Compensation: (1) Where any land is acquired by the State Government\nunder this Chapter, the State Government shall pay for such acquisition\ncompensation in accordance with the provisions

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

1,28,940.26 sq.ft, which has been treated as a trading\nasset, is less than the market price of these rights, and, therefore, these\nrights can only be valued at cost in the accounts\"\n6.3 He submitted that in the case on hand the appellant held 4\nacres of land as stock in trade. It entered into a joint development

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

transferred by the Government under section 32 of the\nKIAD Act, that the role of the Board begins.\nRestraint on expenditure from funds of the assessee\n26. Section 23 stipulates that the assessee shall have the\nauthority to spend such sums as it thinks fit for the\npurposes authorised under this Act from out of Board's\nfunds. Every expense

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

In the result, the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of Section 92-CA; and (ii) any non-resident not being a company, or any foreign company.? 17. As is manifest from a reading of sub-section (13) of Section 144C of the Act, the AO is not accorded any discretion

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1 to 3 of the appeal are general in nature and therefore, the same do not require any specific adjudication. Accordingly, these grounds are dismissed as infructuous. IT(TP)A No.1539/Bang/2024 Page 2 of 37 3. The issue in Ground No. 29 relates to the levy of interest under section 234A and 234B of the Act. Since the levy

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

2), Bengaluru ("Transfer Pricing Office / TPO") for determination of Arm's Length Price under section 92CA of the Act on 30.03.2022. Several notices were issued under section 142(1

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

2) of the Act was issued on 28.08.2015. During the course of assessment proceedings the assessee’s case was referred to Transfer Pricing Officer (TPO) under Section 92CA of the Act. The TPO passed order under Section 92CA of the Act on 31.10.2017 proposing an upward transfer pricing adjustment in respect of the shares sold by the assessee. On receipt

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

2) of the Act was issued on 28.08.2015. During the course of assessment proceedings the assessee’s case was referred to Transfer Pricing Officer (TPO) under Section 92CA of the Act. The TPO passed order under Section 92CA of the Act on 31.10.2017 proposing an upward transfer pricing adjustment in respect of the shares sold by the assessee. On receipt

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

2) of section 40A;* (ii) any transaction referred to in section 80A; IT(TP)A No.370/Bang/2021 Page 33 of 110 (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

2\ndifferent business transferred agreement (BTA) with its holding company\nInfosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the\nF.Y. 2014-15 for transfer of Edge suit of product division for a\nconsideration of Rs. 421 crores. The second BTA was entered as on 17th\nApril 2015 i.e. during

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

transferred by the Government under section 32 of the\nKIAD Act, that the role of the Board begins.\nRestraint on expenditure from funds of the assessee\n26. Section 23 stipulates that the assessee shall have the\nauthority to spend such sums as it thinks fit for the\npurposes authorised under this Act from out of Board's\nfunds. Every expense