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.

section 234B of the Act.” 5. The above grounds relate to two issues, namely re-computation of arm's length price of share sold by the assessee amounting to Rs. 262,27,80,021/- and differential tax on account of difference in rate of tax on capital gains (based on the assessed income

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.

section 234B of the Act.” 5. The above grounds relate to two issues, namely re-computation of arm's length price of share sold by the assessee amounting to Rs. 262,27,80,021/- and differential tax on account of difference in rate of tax on capital gains (based on the assessed income

M/S. BHUWALKA STEEL INDUSTRIES LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

Transfer Pricing for Specified Domestic Transaction vide Finance Act, 2017. Company is having only specified domestic transactions under section 92BA read with 40A(2)(b). 6. The Learned AO and TPO has erred in determining Arm’s Length Price/ Fair Market Value of the transactions with related parties by applying comparable margins on the whole of Company’s turnover

M/S BHUWALKA STEEL INDUSTRIES LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(4), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

Transfer Pricing for Specified Domestic Transaction vide Finance Act, 2017. Company is having only specified domestic transactions under section 92BA read with 40A(2)(b). 6. The Learned AO and TPO has erred in determining Arm’s Length Price/ Fair Market Value of the transactions with related parties by applying comparable margins on the whole of Company’s turnover

DELIVERHEALTH SOLUTIONS INDIA PRIVATE LIMITED (EARLIER KNOWN AS NUANCE TRANSCRIPTION SERVICES INDIA PRIVATE LIMITED),BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, CIRC-2(1)(1), BANGALORE

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 342/Bang/2022 Assessment Year : 2017-18 M/S. Deliverhealth Solutions India Pvt. Ltd. (Earlier Known As Nuance Transcription Services India Pvt. Ltd.) The Joint First Floor, Block B, Commissioner Of Salarpuria Aura, Income Tax, Khata No. 434/170, Circle 2(1)(1), Marathahalli –Sarjapur Outer Vs. Bangalore. Ring Road, Kaverappa Layout, Kadubeesanahalli, Bangalore – 560 103. Pan: Aaacf3465F Appellant Respondent

transfer pricing study of the Appellant and using arbitrary filters for benchmarking the international transaction pertaining to ITeS. 4.1 That on facts and circumstances of the case and in law, the AO/DRP/TPO have erred in applying the turnover filter with lower limit of INR 1 Crore without appreciating that the Appellant's turnover was INR 233.97 crore, and therefore, ought

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

Accordingly, this ground is allowed for statistical purposes

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

transfer pricing adjustment with respect to the manufacturing/ trading segment should be restricted to the amount of international transactions, pertaining to manufacturing / trading segment only instead of entity level transactions. Grounds specific to the trading segment 8. That the Learned AO/ Learned Panel upheld the action of the Learned TPO of rejecting functionally comparable companies listed below, initially selected

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

transfer pricing provisions and settled judicial principles. 42.3 With respect to corporate services, the assessee submits that TEL provides centralized operational services such as finance, treasury, tax, legal, HR, governance, operational excellence, and executive support, which are essential for day-to-day operations and governance of the assessee. Stewardship or shareholder activities, if any, are specifically excluded from charge

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

In the result, the appeal filed by assessee stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 258/Bang/2022 Assessment Year : 2017-18 M/S. Eit Services India Pvt. Ltd., The Deputy #39/40, Digital Park, Commissioner Of Electronic City Phase Income Tax, Ii, Circle – 2(1)(1), Hosur Road, Vs. Bangalore. Bangalore – 560 100. Pan: Aaacd4078L Appellant Respondent Assessee By : Shri Padam Chand Khincha, Ca Revenue By : Shri Praveen Karanth, Cit-Dr Date Of Hearing : 01-11-2022 Date Of Pronouncement : 04-01-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 14/02/2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “1. General Ground 1.1. The Orders Passed By Learned Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income- Tax Officer, National E-Assessment Centre, Delhi (Hereinafter Referred As "Ao" For Brevity), Learned Deputy Commissioner Of Income Tax (Tp) — 1(2)(1), Bangalore (Hereinafter Referred As "Tpo" For Brevity) & The Learned Dispute Resolution Panel - 1, Bengaluru (Hereinafter Referred As "Drp" For Brevity) ("Ao", "Tpo" & "Drp"

transfer pricing study without providing any cogent reasons for the same: a) Adecco India Private Limited b) Anlage infotech India Private Limited c) BNR Udyog Limited — BSS Segment d) Husys Consulting Limited e) International Manpower Resources Private Limited f) MPCON Limited g) Magma Advisory Services Limited h) Talent Maximus India Private Limited i) Teamlease Services Limited j) Verifacts Services Private

EBIX TRAVELS PVT. LTD.,NEW DELHI vs. DCIT,CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result appeal of the assessee is partly allowed

price\nand total operating revenue of the assessee from ticket\nsegment, instead of applying it on the revenue from\nassociated enterprises only.\nV. That the learned AO has also erred both in law and on\nfacts in law in disallowing the claim of depreciation of\n1,845,615/– under section 32 (1) of the act.\nThat while making the aforesaid

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

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

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

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

234B and 234C\nof the Act which is consequential in nature and therefore not requiring\nany separate adjudication. Hence, all these grounds of appeal are\nhereby dismissed as infructuous.\n20.\nThe issue raised by the assessee through Ground Nos.3 to 7 are\ninterconnected and pertains to the taxation of receipt of sale\nconsideration of flats received under JDA as business

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing documentation requirements. Selection of companies earning super normal profits as comparables 3. Erred in selecting certain companies which are earning super normal profits as comparable to the Appellant. Non-provision of adjustment for risk differences 4. a) Erred in not appreciating the fact that the Appellant operates as a risk free service provider and all the key risks