M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

33B, in the circumstances and within the period specified in that section; (iii) it is not formed by the transfer to a new business, of machinery or plant previously used for any purpose. Explanation.—The provisions of Explanations 1 and 2 to sub-section (3) of sec-tion 80-IA shall apply for the purposes of clause (iii) of this

M/S. VMWARE SOFTWARE INDIA PRIVATE LIMITED,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RANGE-7, BENGALURU

In the result, appeal by the Assessee is partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaranassessment Year : 2014-15 M/S. Vm Software India Pvt. Ltd., Vs. Pr. Cit, Kalyani Magnum, Block-1, Iii Floor, 165/2, Range – 7, Doraisanipalya, Iim Post, Bannerghatta Road, Bengaluru. Bengaluru – 560 076. Pan : Aaccv 4573 E Assessee By : Shri. T. Suryanarayana, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Osd)(Itat), Bengaluru Date Of Hearing : 18.11.2021 Date Of Pronouncement : 22.11.2021 O R D E R

transfer pricing assessment for AY 2014-15, the learned TPO had examined the cost plus revenue calculation and passed an order under section 92CA of the Act. It was thus submitted that the AO has duly examined the information filed by the assessee in relation to the difference in revenue as per the invoices raised vis-à-vis revenue recognized

M/S. ALLSTATE INDIA PRIVATE LIMITED ,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

Pricing Agreement, the assessee has filed modified ITR u/s 139 r.w.s. 92CD of the Income- tax Act,1961 ['the Act' for short] on 19.10.2020 declaring income of Rs.23,19,09,830/-. The other statutory notices were issued to the assessee. 2.1 The assessee company is engaged in providing software development services including testing, infrastructure support and other related services

BOSCH LIMITED,BANGALORE vs. ACIT, BANGALORE

Bench: Shri A.K.Garodia, Accounant Member & Smt. Asha Vijayaraghavan

price contract for 4 years beginning on 01-04-2003 (relevant to AY: 2004-05) 719((TP)A2011 & ITA No.1211(B)/15 4. It was submitted by the ld. AR of the assessee that it can be seen in para-9 to 9.1 of the order of the ld. CIT(A) that the assessee has raised an issue before

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri George George K. & Shri Chandra Poojari

transfer, then, for the purposes of the deduction under this section, the profits and gains of the industrial undertaking or the business of the hotel shall be computed as if the transfer, in either case, had been made at the market value of such goods as on that date : Provided that where, in the opinion of the Assessing Officer

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

transferred to a new business in that area or in any other backward area and the total value of the machinery or plant or part so transferred does not exceed twenty per cent of the total value of the machinery or Page 31 of 39 plant used in the business, then, for the purposes of clause (iii) of this