M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

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

Section 144C(13) of the Income Tax Act, 1961. 2. In the present case the TPO had proposed an adjustment of Rs.31,26,65,872/on account of arm's length price vide its order dated 21 .10.2016, out of which the adjustment of Rs.25,23,76,5211- was made in the trading segment, and the adjustment of Rs.6

M/S THE HIMALAYA DRUG COMPANY,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal for Assessment Year 2011-12 is partly allowed

Bench: Shri Jason P Boaz & Shri Laliet Kumarit(Tp)A No.187/Bang/2015 Assessment Year : 2010-11

2) (xv) of the Act if it satisfies otherwise the tests laid down by the law."85. The OECD Transfer Pricing Guidelines, para 7.13 emphasises that there should not be any automatic inference about an AE receiving an entity group service only because it gets an incidental benefit for being part of a larger concern and not to any specific

SANYO INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2007-08 is partly allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazi.T.(T.P) A. No.1195/Bang/2011 (Assessment Year : 2007-08) M/S. Sanyo India Private Limited, Vs. Dy. Commissioner Of Income Tax, No.45, 2Nd Floor, Jublee Building, Circle 12(3), Bangalore. Museum Road, Bangalore-560 025 Pan Aajcs 0730M Appellant Respondent.

2. The learned A.O. has placed incorrect and inappropriate reliance on the judicial precedent in the case of Kedarnath Jute Mfg. Co. Ltd. Vs. CIT (Central), Calcutta (82 ITR 363) (SC) without considering the facts of the case. 3. The learned A.O. has erred in law, by carrying out an arbitrary adjustment on account of advertisement and publicity expense

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

BIOCON LIMTIED,BANGALORE vs. CIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2009-10 is allowed as indicated above

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

Pricing Adjustment of Rs.20,32,95,392 in respect of the international transactions entered into by the assessee with its Associated Enterprises (AEs). The Assessing Officer passed a draft order of assessment under Section 143(3) r.w.s. 144C of the Act dt.30.3.2013 making various additions / disallowances. The assessee filed its objections thereto before the Dispute Resolution Panel

JCIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

CANARA BANK,BANGALORE vs. ADDL. C.I.T., BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

CANARA BANK,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

JCIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

ADDL.CI.T., BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

M/S. CANARA BANK,BANGALORE vs. ACIT, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

CANARA BANK,BANGALORE vs. JCIT, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

ADDL.CIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

35D of an amount of Rs.1,92,50,000/-. 8) The learned CIT(A) erred in confirming the write off of investments of an amount of Rs.24,00,000/- 9) For all these and other grounds that may be urged at the time of hearing the Appellant request that its appeal be allowed. ITA Nos.479 & 530/09, ……693 & 684/B/12 Page

SUBEX LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, Revenue’s appeal is partly allowed

Bench: Shri B. Ramakotaiah & Shri Narendra Kumar Choudhury

Transfer Pricing Officer (TPO) and the TPO determined the TP adjustment of Rs. 3,18,09,842/-. This adjustment has been proposed on advances given to its subsidiary and according to the TPO, since the loans are advanced from India Bond rate of ‘BB rating’ should be considered as against the 6% PA received by assessee. He adopted a rate