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114 results for “transfer pricing”+ Section 247clear

Sorted by relevance

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Key Topics

Section 143(3)61Addition to Income54Section 14A41Disallowance41Section 14336Transfer Pricing36Deduction36Section 10A35Section 153C

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

ITA 84/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

247 (ITATOSB) that there being no liability to pay as principal is retained as capital by conversion into equity shares, it was not borrowing. 7. On the facts and in the circumstances of the case whether or not DRP after concurring with the view of the TPO that the investment in assessee company by the AEs is not for earning

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

ITA 63/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

247 (ITATOSB) that there being no liability to pay as principal is retained as capital by conversion into equity shares, it was not borrowing. 7. On the facts and in the circumstances of the case whether or not DRP after concurring with the view of the TPO that the investment in assessee company by the AEs is not for earning

Showing 1–20 of 114 · Page 1 of 6

30
Section 92C30
Section 153A29
Comparables/TP24

THE HIMALAYA DRUG COMPANY ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE

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

ITA 3071/BANG/2018[2014-15]Status: DisposedITAT Bangalore07 Dec 2020AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

For Appellant: ShriFor Respondent: Shri Pradeep Kumar, CIT-D.R
Section 143(3)

Transfer pricing adjustment of Rs.179.09 crores determined by the TPO. Besides the above, the AO also disallowed expenses relating to Gift to Doctors; expenditure incurred on swimming pool, depreciation/addl. Depreciation claimed on certain assets and donation to CM relief fund. 3.3 The assessee filed its objections before Ld DRP. The Ld Dispute Resolution Panel granted relief in respect of donation

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

247 CTR 334; • the DRP also directed the Ld.AO to recompute the loss arising out of Noida unit against the business income after excluding the transfer pricing adjustment located by assessee in the computation. • DRP also directed to grant TDS credit after verifying the claim of assessee. 20. The Ld.AO upon receipt of DRP directions called upon assessee to file

UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

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

ITA 345/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Aug 2023AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(1)(1), BANGALORE

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

ITA 308/BANG/2023[2017-18]Status: DisposedITAT Bangalore29 Aug 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai, A.R. a/wFor Respondent: Shri Saravanan B., DR
Section 143(3)Section 144BSection 144C(13)Section 14ASection 250Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

M/S. UNITED SPIRITS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 489/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 May 2020AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleit(Tp)A No.489/Bang/2017 (Assessment Year: 2012-13) M/S. United Spirits Limited, Ub Towers, No.24, Vittal Mallya Road, Bangalore-560 001 ….Appellant Vs. Dy. Commissioner Of Income Tax, Circle 7(1)(1), Bangalore. ……Respondent. Assessee By: Shri Perci Pardiwala, Senior Advocate & Shri Ketan Ved, C.A. Revenue By: Shri Bipin C.N, Jcit (D.R) Date Of Hearing : 06.03.2020. Date Of Pronouncement : 29.05.2020. O R D E R Per Shri B.R. Baskaran, A.M. : The Assessee Has Filed This Appeal Challenging The Assessment Order Dated 31-01-2017 Passed By The Assessing Officer For Assessment Year 2012-13 Passed U/S 143(3) R.W.S 144C(13) Of The Act.

For Appellant: Shri Perci Pardiwala, Senior Advocate and Shri Ketan Ved, C.AFor Respondent: Shri Bipin C.N, JCIT (D.R)
Section 143(3)Section 144C(10)Section 144C(13)Section 14ASection 154Section 36(1)(iii)Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

M/S. UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE

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

ITA 2532/BANG/2019[2015-16]Status: DisposedITAT Bangalore19 May 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ankur Pai for Shri K.R. VasudevanFor Respondent: Shri Sankar Ganesh K., D.R
Section 143(3)Section 144C(13)Section 14ASection 37Section 92C

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

M/S. UNITED SPIRITS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BENGALURU

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

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR
Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

Transfer Pricing Adjustment on account of AMP expenses. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee had filed objections before the DRP. The DRP vide

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 544/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 542/BANG/2021[2014-15]Status: DisposedITAT Bangalore07 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 543/BANG/2021[2015-16]Status: DisposedITAT Bangalore07 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

section 34 against the assessee as the karta of a HUF. Further, the High Court had not expressed its opinion on the question based upon section 25 of the 1992 Act. In the result, the order of the High Court was set aside and the appeal was remanded to the High Court for disposal in accordance with

M/S UNITED SPIRITS LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR
Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

Transfer Pricing Adjustment on account of AMP expenses. 31 IT(TP)A No.3091/Bang/2018 M/s.United Spirits Limited. (ii) Assessee has been bearing substantial portion of the fees paid to ICC for acquiring sponsorship rights even though benefit of the same is derived by the other entities of the world. 88. Aggrieved by the addition proposed by the AO, the assessee

DCIT, BANGALORE vs. M/S CISCO SYSTEMS BV - INDIA BRANCH, BANGALORE

In the result appeal filed by revenue stands partly allowed and appeal filed by assessee stands allowed

ITA 309/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Aug 2021AY 2011-12

Bench: Shri Br Baskaran & Smt. Beena Pillaiit(It)A No.309/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Rajan Vora, C.AFor Respondent: Shri Pradeep Kumar, CIT (DR)
Section 1O

247 CTR 334, while the same has not been accepted by the department and a SLP has been filed before the Hon'ble Supreme Court against such order is pending. 4. In the facts and circumstances of the case, whether the Hon’ble. DRP is correct in holding that the foreign exchange transactions are to be considered as operating

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

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

ITA 1228/BANG/2010[2006-07]Status: DisposedITAT Bangalore13 Jan 2016AY 2006-07

Bench: Shri Vijaypal Rao & Shri Inturi Rama Raoi.T. (T.P) A. No.1228/Bang/2010 (Assessment Year : 2006-07) M/S. Textron India Private Limited, (Formerly Known As Textron Global Technology Centre Pvt. Ltd.) Global Village, Rvce Post, Mylasandra, Off Mysore Road, Bangalore-560 059 …. Appellant. Pan Aacct 0118M Vs. Dy. Commissioner Of Income Tax, Circle 12(4), Bangalore. ….. Respondent. Appellant By : Shri P.K. Prasad. Respondent By : Smt. Neera Malhotra, Cit (D.R) Date Of Hearing : 30.11.2015. Date Of Pronouncement : 13.1.2016. O R D E R Per Shri Vijaypal Rao, J.M. :

For Appellant: Shri P.K. PrasadFor Respondent: Smt. Neera Malhotra, CIT (D.R)
Section 133(6)Section 143(3)Section 92C(2)

Transfer Pricing provisions, however, in due course of discussion and adjudication of this issue in a series of decisions of this Tribunal, commonly accepted tolerance range of 5% to 25% of the total revenue from RPT has been considered as reasonable depending upon the facts and circumstances of each case. In the case on hand, the availability of the comparables

CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

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

ITA 520/BANG/2022[2016-17]Status: DisposedITAT Bangalore02 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 520/Bang/2022 Assessment Year : 2016-17 M/S. Cae Flight Training (India) Pvt. Ltd., Survey No. 26 & 27, The Deputy Bandaramanahalli Commissioner Of Village, Income Tax, Anneshwara Panchayat, Central Circle – 2 (2), Kasaba Hobli, Vs. Bangalore. Devanahalli Taluk, Bengaluru – 562 110. Pan: Aadcc1248A Appellant Respondent Assessee By : Shri Ketan Ved, Ca : Shri Sumer Singh Meena, Revenue By Cit Dr-1 Date Of Hearing : 02-08-2022 Date Of Pronouncement : 02-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 12/04/2022 By The Ld.Dcit, Central Circle – 2(2), Bangalore On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, M/S. Cae Flight Training (India) Private Limited (Hereinafter Referred To As The "Appellant") Respectfully Craves Leave To Prefer An Appeal Under Section 253 Of The Income-Tax Act, 1961 ("The Act") Against The Order Passed By The Deputy Commissioner Of Income-Tax, Central Circle

For Appellant: Shri Ketan Ved, CA
Section 253Section 92CSection 92D

section 234B and 234D of the Act which is consequential to the grounds of appeal in above paras; The Appellant submits that each one of our above grounds is without prejudice to the other. The Appellant craves leave to add, modify, amend, alter or delete, any or all of the above grounds of appeal during the course of hearing

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

In the result appeal filed by assessee stands partly allowed

ITA 2565/BANG/2017[2013-14]Status: DisposedITAT Bangalore11 Oct 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2565/Bang/2017 Assessment Year : 2013-14 M/S. Galax E Solutions India Pvt. Ltd., The Assistant Unit No. 4, 8Th Floor, Commissioner Of Innovator Block, Income Tax, Itpl Whitefield Road, Circle – 3(1)(2), Bangalore – 560 066. Vs. Bangalore. Pan: Aabcg9007F Appellant Respondent Assessee By : Shri C.J. Brito, Ca : Shri Rajendra Kumar Revenue By Mishra, Cit (Dr) Date Of Hearing : 24-08-2021 Date Of Pronouncement : 11-10-2021 Order Per Beena Pillai

For Appellant: Shri C.J. Brito, CA
Section 10ASection 143Section 143(3)Section 144Section 92

section 144 C of the Act by the Ld.ACIT Transfer Pricing officer, Circle 3(1)(2), Bangalore on following grounds of appeal: “1. The Learned Transfer Pricing Officer [TPO], Assessing Officer [AO] and Honorable Dispute Resolution Panel [DRP] have erred in law as well as on facts in passing the order which is bad in law and disregarding principle

RADISYS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result appeal filed by assessee stands partly allowed as indicated here and appeal filed by revenue stands dismissed

ITA 94/BANG/2016[2011-12]Status: DisposedITAT Bangalore14 Jun 2021AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.94/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Mahaveer C Jain, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 10Section 10ASection 143(3)Section 271Section 8

Transfer Pricing Order, the Ld.AO passed draft assessment order. In the draft assessment order the Ld.AO disallowed a sum of Rs.24,58,203/- being deduction claimed under section 10A of the Act. The Ld.AO made the disallowance on the ground that, the appeal against decision of Hon’ble Karnataka High Court in case of Tata Elxsi, reported in (2011) 247

ASST.C.I.T., BANGALORE vs. M/S AMETEK INSTRUMENTS INDIA PRIVATE LIMITED, BANGALORE

In the result, the appeal of the assessee is partly allowed, the revenue appeal is dismissed and C

ITA 398/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Sept 2021AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A No.398/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Sharath Rao, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(5)Section 92B

section 143(1) of the Act and the case was selected for scrutiny. The Assessing Officer ("AO") made a reference to the Transfer Pricing Officer ("TPO") to determine the arm's length price ("ALP") of the international transactions of the Assessee with its Associated Enterprises ("AE"). 7.1. AS PER TRANSFER PRICING ("TP") STUDY: For the subject

AMETEK INSTRUMENTS INDIA PVT. LTD.,,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeal of the assessee is partly allowed, the revenue appeal is dismissed and C

ITA 499/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Sept 2021AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A No.398/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri Sharath Rao, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 144C(5)Section 92B

section 143(1) of the Act and the case was selected for scrutiny. The Assessing Officer ("AO") made a reference to the Transfer Pricing Officer ("TPO") to determine the arm's length price ("ALP") of the international transactions of the Assessee with its Associated Enterprises ("AE"). 7.1. AS PER TRANSFER PRICING ("TP") STUDY: For the subject