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Section 143(3)87 Addition to Income59 Transfer Pricing56 Section 92C48 Comparables/TP43 Section 10A33 Section 14830 Section 133A25 Disallowance

MATCHMOVE INDIA PRIVATE LIMITED,BANGALORE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND INCOME TAX OFFICER, WARD 4(1)(3), BANGALORE, BANGALORE

In the result, ground no. 4 of the Appeal is allowed with above direction

ITA 2255/BANG/2024[2021-22]Status: DisposedITAT Bangalore08 Apr 2026AY 2021-22

Bench: Shri Prashant Maharishi & Shri Sounadararajan K.Ittpa No. 2255/Bang/2024 Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Divya K. J – CIT

Section 143(3)

Transfer Pricing Grounds: 3. Adjustment on account of re-determination of ALP for software development services rendered by the Appellant to its AEs amounting to INR 10,25,38,320 3.1. Erred by not accepting the economic analysis undertaken by the Appellant in accordance with the Act and the corresponding Rules, conducting a fresh economic analysis for the determination

INVTEVA PRODUCTS INDIA AUTOMOTIVE PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed in the terms indicated above

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MATCHMOVE INDIA PRIVATE LIMITED,BANGALORE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND INCOME TAX OFFICER, WARD 4(1)(3), BANGALORE, BANGALORE

INVTEVA PRODUCTS INDIA AUTOMOTIVE PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

MATCHMOVE INDIA PRIVATE LIMITED,BANGALORE vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT AND INCOME TAX OFFICER, WARD 4(1)(3), BANGALORE, BANGALORE

INVTEVA PRODUCTS INDIA AUTOMOTIVE PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

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

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

M/S INATECH INDIA PRIVATE LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-3(1)(4), BANGALORE

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

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

NXP INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU

M/S TYCO FIRE & SECURITY INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

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

SOCIETE GENERALE GLOBAL SOLUTION CENTRE PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(2), BENGALURU

YOKOGAWA INDIA LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

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

STERLING COMMERCE PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

HUAWEI TECHNOLOGIES INDIA PVT LTD ,BANGALORE vs. INCOME TAX OFFICER WARD-11(2), BANGALORE

HUAWEI TECHNOLOGIES INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE vs. M/S HUAWEI TECHNOLOGIES INDIA PVT LTD , BANGALORE

ANSR GLOBAL CORPORATION PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

M/S. GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

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