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

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing analysis. The basis for the costs incurred, the activities for which they were incurred, and the benefit accruing to the Taxpayer from those activities must all be proved to determine first, whether, and how much, of such expenditure was for the purpose of benefit of the Taxpayer, and secondly, whether that amount meets ALP criterion. In the present

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer pricing analysis. The basis for the costs incurred, the activities for which they were incurred, and the benefit accruing to the Taxpayer from those activities must all be proved to determine first, whether, and how much, of such expenditure was for the purpose of benefit of the Taxpayer, and secondly, whether that amount meets ALP criterion. In the present

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

viii) Further the scenario is also completely changed after insertion of section 80AB w.e.f 1/4/1981, and, therefore also the appellant's argument is not acceptable. As regards section 80 AB, it is also worthwhile to note that the decision in the cases of Distributors Baroda, Motilal Pesticides and Vijay Industries, the assessment years involved were

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

viii) Further the scenario is also completely changed after insertion of section 80AB w.e.f 1/4/1981, and, therefore also the appellant's argument is not acceptable. As regards section 80 AB, it is also worthwhile to note that the decision in the cases of Distributors Baroda, Motilal Pesticides and Vijay Industries, the assessment years involved were

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

36-38, 38A 19-20, 6. Attribution -- -- 23-25 Add. 26-31 22-26 Ground 7. 80G -- -- -- -- -- 37 Representative 8. -- -- -- -- 34 24-25 assessee Claim for 53-54 53-54 deduction – 9. -- -- -- (Additional (Additional 38 proviso to Grounds) Grounds) 40(a)(i) 10. MAT Credit 24 -- 27 -- -- -- 11. TDS Credit -- 22 26 50 41 41 Incorrect 12. Refund 25 -- -- -- -- -- Calculation

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

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Transfer Pricing Proceedings 36 Without prejudice to the above, the learned TPO erred in not allowing the benefit of the +/-3% range prescribed in the proviso to section 92C(2).” 11.1 Facts of the case are that the Assessee entered into sponsorship agreement dated 23.06.2015 with United East Bengal Football Team Private Limited (“UEBFT”) for sponsorship

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

VIII. Functional filter: Companies trading in auto parts and auto components were only selected. Companies trading in automobile vehicles or secondhand vehicles were rejected.” 4.4 After applying the above filters, the TPO observed that these five companies are good comparables and calculated mean at 4.00%. He further noticed that the assessee’s taxpayer’s margin is 0.94%. The ALP calculated

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

transferred by the Government under section 32 of the\nKIAD Act, that the role of the Board begins.\nRestraint on expenditure from funds of the assessee\n26. Section 23 stipulates that the assessee shall have the\nauthority to spend such sums as it thinks fit for the\npurposes authorised under this Act from out of Board's\nfunds. Every expense

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

transfer the land\nto the Board for the purpose for which the land has been acquired.\"\n28. Section 29 deals with payment of compensation, which is extracted as\nunder:\n“29. Compensation: (1) Where any land is acquired by the State Government\nunder this Chapter, the State Government shall pay for such acquisition\ncompensation in accordance with the provisions