DY.COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2),, AHMEDABAD vs. M/S.QUINTILES RESEARCH INDIA PVT.LTD.,, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the departmental appeal is dismissed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2011-12

4) of section 92C in conformity with the Arm's length price determined under sub-section (3) of section 92CA by the Transfer

QUINTILES RESEARCH (INDIA) PVT. LTD.,BANGALORE vs. THE DY.CIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result, the appeal by the assessee is partly allowed and the\ndepartmental appeal is dismissed

Transfer Pricing Officer shall determine\nthe Arm's length price at least two months before\nthe expiry of new statutory time limit for making\nthe assessment or reassessment.\n\nUnder the existing provisions of sub-section (4

DECATHLON SPORTS INDIA PRIVATE LIMITED,BANGALORE , KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 2(2)(1), BENGALURU, KARNATAKA

In the result appeal of the assessee is partly allowed as indicated\nabove

4. CIT(A)\n5. DR, ITAT, Bengaluru.\nBy order\nAssistant Registrar\nITAT, Bengaluru.", "summary": { "facts": "The assessee, Decathlon Sports India Private Limited, filed an appeal against the assessment order for AY 2020-21, wherein its total income was assessed at Rs. 155,34,29,950/- against a returned income of NIL. The assessment included transfer pricing adjustments and disallowance

SAP INDIA PRIVATE LIMITED,BANGALORE vs. JURISDICTIONAL ASSESSING OFFICER - DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), BANGALORE

The appeal of the assessee is allowed to the extent indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

section 144C (5) of the act wherein the returned income filed by the assessee on 31st of March 2021 declaring total income of ₹ 9,970,661,310 is assessed at ₹ 11,716,843,086. 02. The assessee is aggrieved with the same and is in appeal before us. The assessee is not pressing, ground No. [1] which is general

CONCUR TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1), BANGALORE

Appeal of the assessee is partly allowed as indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

transfer pricing ("TP matter) 3. The learned TPO/ AO erred, in law and in facts, by rejecting comparable companies forming part of the TP study report as well as certain additional comparable companies as they do not appear in TPO's search matrix. 4. The learned TPO/ AO erred in law and in facts by not accepting the economic analysis

M/S. MUKKA PROTEINS LIMITED (FORMERLY KNOW AS MUKKA SEA FOOD INDUSTRIES LTD., ),MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , MANGALURU

In the result, appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Keshav Dubey

price being inflated cannot be ruled out and there is no material to dislodge such finding. The issue is not whether the purchase price reflected in the books of account matches the purchase price stated to have been paid to other persons. The issue is whether the purchase price paid by the assessee is reflected as receipts by the recipients

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

transferred to me.\nI have received salary income of around Rs.25,00,000/- which I will offer as income\nand pay resultant tax. I am not able to explain the sources for the remaining\nRs.40,00,000/-. I offer the same as my additional undisclosed income for the FY\n2013-14.\n3.1. From the above ld. AO observed that assessee

SRI. MARUTHIVANDITH REDDY MANNUR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeal of the assessee in ITA No

transferred to me.\nI have received salary income of around Rs.25,00,000/- which I will offer as income\nand pay resultant tax. I am not able to explain the sources for the remaining\nRs.40,00,000/-. I offer the same as my additional undisclosed income for the FY\n2013-14.\n3.1. From the above ld. AO observed that assessee

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 (“TP) order dated 30.10.2019 under section 92CA of the Act and has made the following adjustments: S Particulars Amount (Rs) No A International Transaction with Associated Enterprises (“AE”) 1. Management Fee 6,00,00,000 2. Payment of Royalty 2,55,70,901 B Specified Domestic Transaction 1. Sales promotion expenses paid to United

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 (“TP) order dated 30.10.2019 under section 92CA of the Act and has made the following adjustments: S Particulars Amount (Rs) No A International Transaction with Associated Enterprises (“AE”) 1. Management Fee 6,00,00,000 2. Payment of Royalty 2,55,70,901 B Specified Domestic Transaction 1. Sales promotion expenses paid to United

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

transfer pricing officer u/s. 92CA(1),\nPage 15 of 86\nIT(TP)A Nos. 303 & 839/Bang/2022\nthe time period to pass an assessment order u/s. 143(3) as per section 153(1) comes to a halt.\n6.12 Be that as it may, after the receipt of an order u/s. 92CA(3) by the Ld.AO, as per section 92CA(4

DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE-4(1)(1), BANGALORE, BANGALORE vs. EYGBS (INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeal by the AO is dismissed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

4) of the Act, it may be noted that the Act specifically denies claim of deduction under section 10AA of the Act on any adjustment made by the Transfer Pricing

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

price so determined. It is further provided that no deduction u/s 10A or section 10AA or section 10B or under Chapter VIA shall be allowed in respect of the amount of income by which the total income of the assessee is enhanced after computation of income under sec. 92C(4). 39.16 As per provisions of sec.92(3), the transfer

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

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

Pricing Addition in respect of interest on External Commercial Borrowings (ECB) and interest on delayed receivable amounting to INR.75,39,13,371/- and INR.29,837/-, respectively. 4. The Assessing Officer passed a Draft Assessment Order, dated 20/12/2023, under the provisions of section 143(3) read with section 144C read with section 144B of the Act incorporating the aggregate Transfer

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

transfer pricing adjustments were examined but it was found that the assessee has incurred the AMP Page 3 of 29 expenses for the benefits of its AE amounting to ₹ 769,019,660/–. The arm's-length margin on that was considered at 19.97% and therefore it was found that arm's-length price of the international transaction

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE, BANGALORE vs. EYGBS (INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the Revenue are dismissed

Bench: Waseem Ahmed & Shri Prakash Chand Yadav

4) of the Act, it may be noted that the Act specifically denies claim of deduction under section 10AA of the Act on any adjustment made by the Transfer Pricing

DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-4(1)(1), BANGALORE, BANGALORE vs. EYGBS (INDIA) PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the Revenue are dismissed

Bench: Waseem Ahmed & Shri Prakash Chand Yadav

4) of the Act, it may be noted that the Act specifically denies claim of deduction under section 10AA of the Act on any adjustment made by the Transfer Pricing

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing officer comes to an end once an order as contemplated under Section 92-CA(4) of the Act has come