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

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

transfer pricing\nanalysis undertaken by the Appellant in accordance with the provision\nof the Act read with Income-tax Rules, 1962 ("the Rules") and holding\nthat the Appellant's impugned international transactions pertaining to\ntrading segment, payment of intra group services and trade receivables\nare not at arm's length.\nAdjustment on account of trading segment\n4.\nThe

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

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

Transfer Pricing addition of INR.62,88,86,271/- is set aside Ground No.1.1 to 1.7 raised by the Assessee are allowed for statistical purposes. Ground No.2 25. Ground No. 2 raised by the Assessee pertains to initiation of penalty proceedings under Section 270A

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

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

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")

transfer pricing adjustment to international transactions of the Appellant and thereby making adjustment to third party transactions as well which is against TP principles. Page 4 IT(TP)A No. 192/Bang/2022 Consequential grounds: 5. The Ld. AO have erred in initiating penal proceedings under section 274 read with section 270A of the Act. 6. The Ld. AO have erred

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

2. On the facts and circumstances of the case and in law, the NFAC, pursuant to directions issued by Hon'ble DRP, erred in making an upward adjustment to the transfer price of the Appellant international transactions in respect of the software development ('SWD1) Services segment (Amounting to INR 129,944,007). Grounds relating to Transfer Pricing

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)

270A r.w.s. 274 of the Act. 11:2 The Appellant craves leave to add, alter, amend and/or substitute and/or modify in any manner whatsoever modify all or any of the foregoing grounds of appeal at or before the hearing of the appeal. 2. Brief facts of the case are as under: The assessee is a company engaged in provision

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

2. On the facts and in the circumstances of the case and in law, the order dated 22 October 2024 passed by Ld. AO, under section 143(3) read with section 144C(13) read with section 144B of the Act, is barred by limitation under section 153 of the Act, and is thus void-ab-initio, illegal

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

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

2. On facts and in the circumstances of the case and in law, the Hon’ble DRP/ Learned AO/ Learned TPO erred in making an upward adjustment / addition on account of: 2.1 Transfer Pricing adjustment on account of provision of software development and support services to its Associated Enterprises (‘AEs’) amounting to Rs. 267,20,51,914 2.2 Transfer Pricing

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

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

2 IT(TP)A No.293/Bang/2022. NTT DATA Information Processing Services Pvt.Ltd. 3. Ld. AO/TPO pursuant to the directions of the Hon'ble DRP, erred in making addition of INR 78,56,31,349 to total income of Appellant alleging that prices charged by the Appellant for software development services and IT enabled services rendered to its associated enterprises

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 at Rs. 2

MMSH CLINICAL RESEARCH PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed as indicated above

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Year: 2021-22

2. The Ld. AO / Ld. TPO erred in fact and in law by disregarding the working capital adjustment proposed by the Assessee, which is critical for ensuring a fair and accurate determination of the arm's length price thus making an addition of Rs. 5,04,48,986. 3. The Ld. AO / Ld. TPO erred in rejecting the filters applied

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. M/S. FLIPKART INDIA PVT LTD., BENGALURU

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

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

Transfer Pricing Officer. 7. The Ld. CIT(A) has erred in law and on facts by contending that the Appellant is liable to deduct tax on ESOP cross charge payments under both Section 192 and Section 195 of the Act, against settled principles of law, without appreciating that the same would result in double taxation of same amount

M/S. FLIPKART INDIA PVT. LTD.,BANGALORE vs. ACIT, SPECIAL RANGE-3, BANGALORE

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

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

Transfer Pricing Officer. 7. The Ld. CIT(A) has erred in law and on facts by contending that the Appellant is liable to deduct tax on ESOP cross charge payments under both Section 192 and Section 195 of the Act, against settled principles of law, without appreciating that the same would result in double taxation of same amount

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

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 of interest under section 234A and 234B is consequential in nature and dependent on the outcome of the assessment which is under appeal. Hence, this ground is also dismissed as infructuous