SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] M/s. Bhavana Co op Credit Society Niyamitha, Sirsi Page 15 of 31 [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

Transfer Pricing Officer” shall have the same meaning as assigned to in the Explanation to section 92CA.] [(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Not withstanding anything contained in sub-section

SHRI. NAGARAJ VINAYAK JOSHI,KARAWAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahu

section 263 of the Act, which read as under :- “Revision of orders prejudicial to revenue. 263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 89[or the Transfer Pricing

SHRI. NAGARAJ VINAYAK JOSHI,KARAWAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) , BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahu

section 263 of the Act, which read as under :- “Revision of orders prejudicial to revenue. 263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 89[or the Transfer Pricing

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

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production

INCOME-TAX OFFICER, WARD-1 , BELLARY vs. M/S. SOUTH WEST MINING LIMITED, BELLARY

In the result, appeal of the revenue is dismissed and CO filed by the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2011-12 Ito M/S. South West Mining Limited Aayakar Bhavan Staff Road Vidya Nagar Fort Bellary Near Talur Cross Karnataka Toranagallu Vs. Bellary 583 201 Karnataka Pan No : Aafcs9792M Appellant Respondent C.O. No.4/Bang/2023 (Arising Out Of Ita No.457/Bang/2023) Assessment Year: 2011-12 M/S. South West Mining Limited Ito Vs. Bellary 583 201 Ward-1 Karnataka Bellary Appellant Respondent Assessee By : Shri Rakesh Joshi, A.R. Revenue By : Ms. Neera Malhotra, D.R. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 08.02.2024 O R D E R Per Chandra Poojari: This Appeal By Revenue & Co By Assessee Are Directed Against The Order Of Nfac For The Assessment Year 2011-12 Dated 21.4.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Revenue In This Appeal Raised Following Ground: “Whether The Ld. Cit(A) Is Justified On The Facts Of The Case & In Law, In Deleting The Addition Of Rs.287.72 Crores Claimed Towards “Mine Development Expenditure” U/S 37(1) In The Computation Of Income Which Was Not Routed Through The Profit & Loss Account.”

1,39,740 tons of lignite equivalent to excavation-charges of Rs. 11.09 crores However, the Assessee Company was not able to raise any invoice on BLMCL as RERC had not approved the transfer price of the lignite till the year end. The ad-hoc approval of the lignite transfer price from RERC was received only in October 2011. Only

SRI. GIREESHSHASTRI SHANKARSHASTRI JEERE ,GAJENDRAGAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2018-19 Shri Gireeshshastri Shankarshastri Jeere, The Principal Commissioner Of Prop : Fakeeresh Fuels, Income Tax (Central), Kustagi Road, Main Road, Vs. Bengaluru. Gajendragad – 582 114. Pan : Agupj 2460 M Appellant Respondent Assessee By : Shri. R. Chandrashekar, Advocate Revenue By : Shri. D. K. Mishra, Cit (Dr)(Itat), Bengaluru. Date Of Hearing : 15.06.2023 Date Of Pronouncement : 16.06.2023

section 263 of the Act, which read as under :- “Revision of orders prejudicial to revenue. 263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 89[or the Transfer Pricing

M/S. TOKAI RIKA MINDA INDIA PVT. LTD,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX(CENTRAL), BENGALURU

In the result, appeal of the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2018-19

Transfer Pricing The grounds mentioned hereinafter are without prejudice to one another. 1. The Principal Commissioner of Income-Tax (Central) [PCIT]j erred in invoking the powers under Sec. 263 to extend the statutory time limit given to the AO/TPO in completing assessment, which is illegal exercise of power; 2. The PCIT erred in invoking the power under Section

VINOD KUMAR SINGHAL ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-3, BENGALURU

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

Bench: Shri. Laxmi Prasad Sahuandshri. Soundararajan Kassessment Year : 2014-15

section 263 of the Act hereunder: “263. Revision of orders prejudicial to revenue. (1)The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine Page 11 of 14 the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer [or the Transfer Pricing

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

Transfer Pricing Officers tend to take a conservative view. The correction of such view take very long time with the existing appellate structure. With a view to provide speedy disposal, it is proposed to amend the Income-tax Act so as to create an alternative dispute resolution mechanism within the income-tax department and accordingly, section 144C has been proposed

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

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer as per agreement dated

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer as per agreement dated

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer as per agreement dated

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

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information