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

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

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

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

1), the value so adopted or assessed or assessable by such authority shall be taken as the full value of the consideration received or accruing as a result of the transfer. 31. General background of Section 50C a) Generally, in a transaction of transfer of land or building or both (‘asset”) there is a considerable time gap between the date

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands\ndismissed and the cross objections being C

v DCIT (2018) 96\ntaxmann.com 428 (Kolkata-Trib.) is squarely applicable to\nthe facts of the present case. In the aforesaid case, the\nTribunal rendered decision in the context of India-USA\nDTAA. The Tribunal held that the act of securing orders\nand soliciting business by the foreign marketing\ncompanies does not make available any technical\nknowledge or technical service

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

transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

v DCIT (2018) 96 taxmann.com 428 (Kolkata-Trib.) is squarely applicable to the facts of the present case. In the aforesaid case, the Tribunal rendered decision in the context of India-USA DTAA. The Tribunal held that the act of securing orders and soliciting business by the foreign marketing companies does not make available any technical knowledge or technical service

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

v DCIT (2018) 96 taxmann.com 428 (Kolkata-Trib.) is squarely applicable to the facts of the present case. In the aforesaid case, the Tribunal rendered decision in the context of India-USA DTAA. The Tribunal held that the act of securing orders and soliciting business by the foreign marketing companies does not make available any technical knowledge or technical service

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

v DCIT (2018) 96 taxmann.com 428 (Kolkata-Trib.) is squarely applicable to the facts of the present case. In the aforesaid case, the Tribunal rendered decision in the context of India-USA DTAA. The Tribunal held that the act of securing orders and soliciting business by the foreign marketing companies does not make available any technical knowledge or technical service

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

36,13 103,01,34,0 309,04,02,09\n-16\n2\n2\n33\n9\n2016\n309,04,02,09 3035,54,78,4 3344,58,80,5 836,14,70,1 2508,44,10,4\n-17\n9\n80\n79\n45\n34\n2017\n2508,44,10,4\n2508

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

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

v) r.w.s 53A of the\nTransfer of Property Act, and the ratio laid down in the\nabove judgements became the settled position of law till the\n assessment year 2016-17 and thereafter an amendment\nwas made by inserting a new provision of section 45(5A) of\nthe Act applicable with effect from assessment year 2017-18\nand onwards.\n18.The

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

Transfer Pricing Officer' was brought into existence by the Finance Act, 2002 w.e.f. 1.6.2002. Under this provision, the onus of computing ALP of the international transactions in certain cases was shifted to the TPO, who was supposed to pass his order under sub-section (3). There was no separate time limit for passing of the order

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

v) any transaction, referred to in any other section under Chapter VI-A or section 10AA, to which provisions of sub- section (8) or sub-section (10) of section 80-IA are applicable;” Hence, it is pertinent to refer to the provisions of sec.80IA(8), which read as under:- “80IA(8) Where any goods or services held for the purposes

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

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

36 taxmann.com 350 (Mum-Trib) which has held that where an assessee sold controlling interest in a company, addition on account of control premium is justified. In the said decision, the Bench has relied on the report by Phillip Sounders Jr (Phd) which showed that the mean control premium varied from 30% to 50% of quoted price. The relevant observations

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

36 taxmann.com 350 (Mum-Trib) which has held that where an assessee sold controlling interest in a company, addition on account of control premium is justified. In the said decision, the Bench has relied on the report by Phillip Sounders Jr (Phd) which showed that the mean control premium varied from 30% to 50% of quoted price. The relevant observations