IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

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

Transfer Pricing Officer,\nwhere the assessee had maintained information and documents as prescribed\nunder section 92D, declared the international transaction under Chapter X, and,\ndisclosed all the material facts relating to the transaction; and\n(e)the amount of undisclosed income referred to in section 271AAB.\n(7)The penalty referred to in sub-section (1) shall

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal

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

DECATHLON SPORTS INDIA PRIVATE LIMITED,BANGALORE , KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 2(2)(1), BENGALURU, KARNATAKA

In the result appeal of the assessee is partly allowed as indicated\nabove

sections": [ "143(3)", "144B", "92CA(3)", "37(1)", "234B", "270A" ], "issues": "Whether the transfer pricing adjustments for the trading segment

ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing analysis, the purpose is not to compare profit of the tested party with that of the comparables but the purpose is to compare the prices charged by the tested, party with the prices charged by the comparables although when TNMM is adopted as MA.M, the process of such price comparison is by comparing profits of tested party with

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

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

transfer pricing adjustments were examined but it was found that the assessee has incurred the AMP Page 3 of 29 expenses for the benefits of its AE amounting to ₹ 769,019,660/–. The arm's-length margin on that was considered at 19.97% and therefore it was found that arm's-length price of the international transaction

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB. (7)The penalty referred to in sub-section (1) shall be a sum equal

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

1: In re-computing the arm's length price ("ALP") for the international transaction relating to payment of interest on External Commercial Borrowings IT(TP)A No.2525/Bang/2024 Assessment Year 2021-2022 ("ECBs") and making an upward adjustment of INR.62,88,86,271/- 1.1. The learned TPO/ AO has erred in determining a transfer pricing adjustment on account of the interest

APTEAN INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 422/Bang/2022 Assessment Year : 2017-18 M/S. Aptean India Pvt. Ltd., 1/2, 8Th Floor, Level 5, The Assistant Golden Heights, Commissioner Of 59Th C Cross Road, Income Tax, 4Th M Block, Circle – 1(1)(1), Rajajinagar, Vs. Bangalore. Bangalore – 560 010. Pan: Aaacc5890M Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Shri Praveen Karanth, Cit- Revenue By Dr Date Of Hearing : 03-11-2022 Date Of Pronouncement : 20-01-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 25/03/2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another General Ground 1. On The Facts & In The Circumstances Of The Case & In Law, Final Assessment Order Passed By National Faceless

1)] post providing effect to the learned Panel's directions is determined at INR 107,403,656. Grounds relating to other than transfer pricing matters: Grounds relating to disallowance of reimbursement of expenses made to related enterprises under section 40(a)(i) of the Act: 12. On the facts and in the circumstances of the case

MARVELL INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

270A of the Act.” 3. The relevant facts in brief are that the Assessee is a company engaged in design, development and testing of integrated circuits and provides services to its group companies. For the Assessment 2 Assessment Year 2020-2021 Year 2020-2021, the Assessee had filed its return of income on 07/01/2021 declaring total income of INR.72

CARL ZEISS INDIA (BANGALORE) PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 192/Bang/2022 Assessment Year : 2017-18 M/S. Carl Zeiss India (Bangalore) Pvt. Ltd., The Deputy Plot No. 3, Jigani Link Road, Commissioner Of Bommasandra Industrial Income Tax, Area, Circle 2 (1)(1), Bengaluru – 560 099. Vs. Bengaluru. Pan: Aadcc6152H Appellant Respondent : Shri Nageshwar Rao, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 12-04-2023 Date Of Pronouncement : 16-06-2023 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Assessment Order Dated 25.01.2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, Carl Zeiss India (Bangalore) Private Limited (Hereinafter Referred To As "Carl Zeiss India" Or "The Appellant"), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income- Tax Officer, National Faceless Center, Delhi (Hereinafter Referred To As "Ld. Assessing Officer" Or The "Ld. Ao"), Dated 25 January 2022 For The Assessment Year ("Ay")

270A of the Act. 6. The Ld. AO have erred in issuing a demand notice under section 156 of the Act. The Appellant submits that each of the above grounds is independent and without prejudice to one another. The Appellant craves leave to add. alter, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time

MICROCHIP TECHNOLOGY (INDIA) PRIVATE LIMITED ,BENGALURU vs. DCIT CIRCLE 4(1)(1), BMTC BUILDING, KORAMANGALA

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19

section 270A of the Act. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify the grounds herein below or produce further documents before or at the time of hearing of this Appeal.” 2. Brief facts of the case are as under: 2.1 Assessee is a company engaged in the business of rendering software engineering application

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 177/Bang/2022 (Assessment Year: 2017-18)

transfer pricing study report. i. E-Zest Solutions Ltd. ii. Melstar Information Technologies Limited iii. Nintec Systems Limited iv. Yudiz Solutions Pvt. Limited 3 : 8 The Ld. AO/TPO/DRP have erred in rejecting the following additional comparable companies considered by the Appellant at the time of the assessment before the Ld.TPO and the DRP proceedings. i. Indianic Infortech Limited ii. Batchmaster

WEG INDUSTRIES (INDIA) PRIVATE LIMITED,BENGALURU vs. ASSESSING OFFICER, BMTC BUILDING

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

1. On the facts and in the circumstances of the case and in law, the final assessment order (Order') passed by the Assessment Unit, Income-tax Department ('Ld. AO') dated 22 October 2024, under section 143(3) read with section 144C(13) read with section 144B of the Income- tax Act, 1961 ('the Act'), in conformity with the directions

AB INBEV GCC SERVICES INDIA PRIVATE LIMITED,BANGALORE, KARNATAKA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1) , BANGALORE

In the result, appeal is allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.1635/Bang/2024 Assessment Year :2020-21

transfer pricing adjustment made of INR 84,04,860 under section 10AA of the Act. Part II - Corporate tax adjustments: 5. Grounds against addition on account of unbilled revenue amounting to INR 81,26,36,474 5.1 That on the facts of the case and in law, the Ld. AO has grossly erred in making addition

BIOCON BIOLOGICS LIMITED,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), BANGALORE

Appeal of the assessee is partly allowed for\nstatistical purposes

Transfer Pricing Officer (learned TPO', 'Ld. TPO') and\ndirections of the Hon'ble DRP are based on incorrect\nappreciation of facts of the case and incorrect interpretation\nof law and therefore, are bad in law and are liable to be\nquashed.\n3. The Ld. AO erred in assessing total income of the\nAppellant

M/S. PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

transfer pricing (‘TP’) documentation maintained by the Appellant under Section 92D of the Act, in good faith and with due diligence; 6.2. Rejecting the filters selected by the Appellant as captured in the TP documentation and adopting certain addition filters which are not in accordance with the jurisprudence laid down by various appellate forums; 6.3. Application of related party transaction

NTT DATA INFORMATION PROCESSING SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

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

transfer pricing adjustment on account of interest on outstanding receivables amounting to INR 1,09,74,490; 9.2 Without prejudice to our ground of appeal no. 9.1 above, Ld. AO/TPO pursuant to the directions of the Hon'ble DRP erred, in law and facts, by not appreciating that the outstanding trade receivables from its AEs arise from the provision

LOWES SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(1),, BANGALORE

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

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

transfer pricing adjustment on account of the interest on outstanding receivables amounting to INR 1,98,60,669/-. Without prejudice to our ground of objection 3.1 above, the Ld. AO/TPO/DRP erred in law and in facts: Page 3 of 15 a) By not appreciating that the outstanding trade receivables from AEs are arising from provision of software development services