EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

price allocation. Based on such valuation, the total purchase consideration was allocated to identifiable intangible assets such as business contracts, technology, and goodwill, and depreciation was claimed under section 32 of the Act. ITA Nos.290 - 294/Bang/2025 Page 23 of 53 30.1 The learned AR pointed out that the AO originally disallowed the claim on the ground that the assets were

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan K

price allocation. Based on such valuation, the total purchase consideration was allocated to identifiable intangible assets such as business contracts, technology, and goodwill, and depreciation was claimed under section 32 of the Act. 30.1 The learned AR pointed out that the AO originally disallowed the claim on the ground that the assets were not eligible intangible assets. However

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 4,88,31,525 issued by the tax payer on behalf of its Associated Enterprise ("AE") u/s 92CA of the Income-tax Act, 1961 ("the Act"). 2. The learned

SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

Bench: Shri. Abraham P. George

35. The Transfer Pricing Officer's report is, subsequent to the Finance Act, 2007, binding on the Assessing Officer. Thus, it becomes all the more important to clarify the extent of the Transfer Pricing Officer's authority in this case, which is to determining the arm's length price for international transactions referred to him or her by the Assessing

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

In the result, the appeal filed by the assessee is treated as partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

35(1)(iv) as Scientific research expenses shall become academic and we are not adjudicating them. 7. The fifth issue relates to the transfer pricing adjustment made by TPO/AO. This adjustment consists following three items:- (a) Adjustment for interest on advances given to Overseas subsidiaries. (b) Adjustment made for Corporate guarantee commission. (c) Adjustment for Specified Domestic Transaction

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

ii) any transaction referred to in section 80A; IT(TP)A No.370/Bang/2021 Page 33 of 110 (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred

M/S VOLVO INDIA PVT. LTD. vs. ACIT, BANGALORE

In the result, appeal of the Assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. 6. It is not in dispute that the Assessee is an eligible Assessee and therefore the Assessment in the case of the Assessee is to be completed keeping in mind the statutory provisions of Sec.143(3), 144C and Sec.153

NABHIRAJ RATNA BALRAJ BY LEGAL HEIR B.R.RAKESH,BANGALORE vs. INCOME-TAX OFFICER, WARD-7(2)(1), BANGALORE

In the result the appeal of the assessee is allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2016-17

35 and section 37 of the Wealth- tax Act, 1957 (27 of 1957), shall, with necessary modifications, apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation 1.—For the purposes of this section, "Valuation Officer" shall have the same

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

transferred from unit to port of shipment. d) Fulfillment of NFE by EO U/EHTP/STP/BTP units in regard to such exports shall be reckoned on basis of price at which goods are supplied by EOUs to other Exporter or other EOU/EHTP/STP/BTP/SEZ unit. IT(TP)A Nos.99/Bang/2014, 398/Bang/2015, 222/Bang/2016, 492/Bang/2017, 2851/Bang/2-17, 3115/Bang/2018, 151/Bang/2014, 467/Bang/2015 & 609/Bang/2016 M/s. Wipro Limited, Bangalore Page

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

transferred from unit to port of shipment. d) Fulfillment of NFE by EO U/EHTP/STP/BTP units in regard to such exports shall be reckoned on basis of price at which goods are supplied by EOUs to other Exporter or other EOU/EHTP/STP/BTP/SEZ unit. IT(TP)A Nos.99/Bang/2014, 398/Bang/2015, 222/Bang/2016, 492/Bang/2017, 2851/Bang/2-17, 3115/Bang/2018, 151/Bang/2014, 467/Bang/2015 & 609/Bang/2016 M/s. Wipro Limited, Bangalore Page