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77 results for “transfer pricing”+ Section 391clear

Sorted by relevance

Mumbai274Delhi266Karnataka244Ahmedabad88Bangalore77Jaipur48Kolkata35Pune33Chennai31Hyderabad20Chandigarh19Indore17SC7Visakhapatnam7Cochin6Surat4Calcutta4Telangana4Lucknow3Cuttack3Amritsar3Guwahati2Andhra Pradesh1

Key Topics

Addition to Income58Section 143(3)43Section 10A41Disallowance33Section 132(4)32Section 92C29Transfer Pricing27Section 153A24Comparables/TP

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

Section 144C(5) of the Act. The TPO revised the TP Addition in respect of ECB from INR.75,39,13,371 to INR.62,88,86,271/- vide order dated 22/01/2024. Thereafter, the Assessing Officer passed final Assessment Order, dated 24/10/2024, making Transfer Pricing Addition of INR.62,88,86,271/- in respect of interest on ECB. 6. Being /aggrieved, the Assessee

Showing 1–20 of 77 · Page 1 of 4

18
Section 153C17
Deduction17
Section 13215

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

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

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

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R
Section 143(3)

section 10A." Thus it is clear that the Tribunal has followed the earlier order for the Assessment Year 2004-05 which has been upheld by the Hon'ble jurisdictional High Court. Following the earlier order of this Tribunal as well as Hon'ble jurisdictional High Court, we decide this issue in favour of the assessee and against the revenue

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

ITA 370/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jun 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sandeep Huilgol, AdvocateFor Respondent: Dr. Manjunath Karkihallli, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(2)Section 143(3)Section 80G

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

STERLING COMMERCE PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal by the Assessee is partly allowed

ITA 1497/BANG/2010[2006-07]Status: DisposedITAT Bangalore28 Jun 2019AY 2006-07

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaran

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

transfer pricing adjustment u/s 92CA, by the TPO for the ITES segments was erroneous. We have considered the submissions made by the assessee. This issue has been discussed by the TPO in para 2.8 of his order. In this case the TPO had asked the assessee to submit the details and nature of recovery of expenses received

ANSR GLOBAL CORPORATION PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

In the result, the appeal is partly allowed

ITA 225/BANG/2021[2016-17]Status: DisposedITAT Bangalore19 Apr 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathyit(Tp)A No.225/Bang/2021 Assessment Year : 2016-17 M/S. Ansr Global Corporation Pvt. Ltd., Acit, Vs. Ground Floor, Block L1, Circle – 1(1)(1), Manyata Embassy Business Park, Bengaluru. Sez, Outer Ring Road, Nagwara, Bengaluru-560 045. Pan : Aaecn 7296 E Appellant Respondent

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 92Section 92(1)Section 92B(1)

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

M/S SASKEN TECHNOLOGIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

Accordingly this ground raised by assessee stands allowed

ITA 2471/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Aug 2021AY 2013-14

Bench: Shri Br Baskaran & Smt. Beena Pillai

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Shri Pradeep Kumar, CIT(DR)
Section 92CSection 92C(2)

transfer of rights (including granting of a licence) in respect of any copyright, literary, artistic or scientific work, falls under the definition of ‘Royalty’ under the IT Act. 4.25 The revenue has not been able to produce any agreement to establish the payment of royalty by the associated enterprises to assessee. It is also not been established that

M/S CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PVT LTD ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BANGALORE

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

ITA 713/BANG/2017[2012-13]Status: DisposedITAT Bangalore24 Nov 2021AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 92C

Transfer Pricing Officer ("TPO") has erred in computation of markup of the Company. 71. The ld. DR submitted that this company was rejected on application of upper turnover filter and upheld the application of the related party transaction filter applied by the TPO. Hence, the contention regarding the turnover and related party transaction filter are not acceptable. With regard

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

transfer pricing officer. The Ld.TPO called for economic details of the international transaction in form 3CEB. The Ld.TPO issued notice on 05/09/2014. The assessee filed all requisite details. The Ld.TPO examined the international transactions. The Ld.TPO noted that the assessee had entered into following international transactions with its AE. Page 13 IT(TP)A No. 718/Bang/2017 The Ld.TPO noted that

M/S. HIMALAYA WELLNESS COMPANY (FORMERLY KNOWN AS THE HIMALAYA DRUG COMPANY),BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(1), BENGALURU

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

ITA 259/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Jun 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.259/Bang/2022 : Asst.Year 2017-2018 M/S.Himalaya Wellness Company The Deputy Commissioner Of (Formerly Known As The Himalaya Income-Tax, Circle 6(1)(1) V. Bengaluru. Drug Company), Makali, Tumkur Road Bengaluru – 562 162. Pan : Aadft3025B. (Appellant) (Respondent)

For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Sri.Sumer Singh Meena, CIT -DR
Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 2(11)Section 92C

Transfer Pricing Officer (TPO) on 03.09.2019 to determine the Arm’s Length Price (ALP) in respect of the international transactions entered by the assessee with its Associated Enterprises (AEs). The TPO vide his order u/s 92CA(3) of the I.T.Act dated 25.01.2021 suggested an adjustment of Rs.231,39,79,272, which is as under:- Particulars TP Adjustment (in Rs.) Sale

ATOS IT SERVICES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BANGALORE

In the result, the appeal by the assessee is partly allowed

ITA 226/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Aug 2022AY 2016-17

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

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 92B(2)Section 92C

pricing exercise would therefore fail. Therefore in keeping with the OECD guidelines, endeavor should be made to bring in comparable companies for the purpose of broad comparison. Therefore the working capital adjustment as claimed by the Assessee should be allowed. We hold and direct accordingly.' 16. Respectfully following the aforesaid decision, we hold that the working capital adjustment as claimed

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 556/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

transfer pricing. Ground No. 17: Without prejudice to our contention that the provision for onerous lease is an ascertained liability, the provision reversed during the year amounting to INR 2,50,68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 492/BANG/2015[2010-11]Status: DisposedITAT Bangalore19 Jan 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

transfer pricing. Ground No. 17: Without prejudice to our contention that the provision for onerous lease is an ascertained liability, the provision reversed during the year amounting to INR 2,50,68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded

ITO, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 402/BANG/2016[2011-12]Status: DisposedITAT Bangalore19 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

transfer pricing. Ground No. 17: Without prejudice to our contention that the provision for onerous lease is an ascertained liability, the provision reversed during the year amounting to INR 2,50,68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded

DCIT, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

ITA 459/BANG/2015[2010-11]Status: DisposedITAT Bangalore19 Jan 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Vikram Raghavan, AdvocateFor Respondent: Shri Arunkumar, CIT(DR)(TP)(ITAT), Bengaluru
Section 10ASection 10A(4)Section 143(3)Section 155

transfer pricing. Ground No. 17: Without prejudice to our contention that the provision for onerous lease is an ascertained liability, the provision reversed during the year amounting to INR 2,50,68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded

NEOGENETICS FOODS PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

ITA 361/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Feb 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.361/Bang/2021 Assessment Year : 2016-17 M/S. Neogenetics Foods Private Limited, Vs. Dcit, Level 14 & 15, Concorde Towers, Ub City, 1 Circle - 3(1)(1), Vittal Malya Road, Ub City, Bengaluru. Bengaluru – 560 001. Pan : Aadcn 7689 L Assessee Respondent Assessee By : Shri. Narendra Kumar Jain, Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 03.02.2022 Date Of Pronouncement : 07.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 144CSection 92BSection 92C

Transfer Pricing Officer (TPO) to whom a reference was made by the AO u/s.92C of the Act, rejected the TP analysis of the assessee and conducted a fresh TP analysis by considering the assessee as the tested party. The TPO has adopted TNMM as most appropriate method for all the transactions. The TPO selected 5 companies as comparable

M/S. TE CONNECTIVITY SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

ITA 300/BANG/2021[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.300/Bang/2021 Assessment Year : 2016-17

For Appellant: Shri Sriram Sheshadri & Ms. Amulya K., CAsFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)

section 144C(5) of the Act ("DRP Directions"), is beyond jurisdiction, in contravention of the provisions of the Act and invalid. IT(TP)A No.300/Bang/2021 Page 15 of 44 2. The Ld. AO erred in passing the Impugned Order without giving effect to the relief granted to the Appellant by the Hon'ble DRP in relation to the transfer pricing

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

In the result, appeal by the Assessee is allowed and the appeal by the Revenue is dismissed

ITA 202/BANG/2018[2015-16]Status: DisposedITAT Bangalore25 Apr 2018AY 2015-16

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

For Respondent: Shri C.H. Sundar Rao, CIT
Section 131

391. Thus, the assessee-company sustained a loss of Rs. 27,02,398 but it did not claim that loss in the return on the ground that the transfer in question was made to its own subsidiary. The ITO valued the shares transferred by the assessee-company to its subsidiary at the market rate and on that basis came

LOGIX MICROSYSTEMS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeal is partly allowed

ITA 186/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Jan 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B R Baskaranit(Tp)A No.453/Bang/2015 & It(Tp)A No.186/Bang/2016 Assessment Years : 2010-11 & 2011-12

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

Transfer Pricing provisions incorporated in Sec.92 of the Act, deserves to be rejected as without merit. Similarly in Grd.No.5(h) the Assessee seeks to contend that the foreign AE must be regarded as tested party. The contention is devoid of merits and is flawed for the reason that the geographical and other economic circumstances of the comparable companies outside

LOGIX MICROSYSTEMS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal is partly allowed

ITA 453/BANG/2015[2010-11]Status: DisposedITAT Bangalore29 Jan 2020AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B R Baskaranit(Tp)A No.453/Bang/2015 & It(Tp)A No.186/Bang/2016 Assessment Years : 2010-11 & 2011-12

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

Transfer Pricing provisions incorporated in Sec.92 of the Act, deserves to be rejected as without merit. Similarly in Grd.No.5(h) the Assessee seeks to contend that the foreign AE must be regarded as tested party. The contention is devoid of merits and is flawed for the reason that the geographical and other economic circumstances of the comparable companies outside

DELL INDIA PRIVATE LTD.,,BANGALORE vs. JCIT, BANGALORE

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

ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11

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

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92C

391 8. Rejection of VAT refund claimed as deduction (3,050,789) 86. The AO rejected the above reconciliation submitted by the assessee and made an addition to the tune of Rs.319,62,03,391/-. The DRP granted relief to the Assessee in respect of all the additions, except the addition on account of deferred revenue i.e., smart debits deferred