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

C\" BENCH: BENGALURU\nBEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT\nAND\nSHRI SOUNDARARAJAN K., JUDICIAL MEMBER\nSA No.60/Bang/2024\n&\nIT(TP)A No. 1874/Bang/2024\n Assessment year: 2020-21\nVs.\nThe Deputy Commissioner\nof Income Tax,\nCircle 2(2)(1),\nDecathlon Sports India\nPrivate Limited,\nSurvey No.78/10, A2,\nChikkajala Village,\nBellary Road,\nBangalore - 562 157.\nPAN: AAACL 9861H\nAPPELLANT\nBangalore.\nRESPONDENT

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

C” BENCH, Bangalore BEFORE SHRI PRASHANT MAHARISHI, Vice President AND SHRI SOUNDARARAJAN K, JM ITA No 1519 /Bang/2024 A. Y. 2020 – 21 Appellant Respondent M/s SAP India private The Deputy Commissioner of limited income tax Circle – 6 (1) (1), sixth floor, Bengaluru RMZ Ecoworld, second floor, Plot C1, 8A campus, BMTC building, Sarjapur Marathahalli 80 Feet Road, Outer Ring Road

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

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

C does not envisage or contemplate the interdiction or involvement of the transfer pricing officer once a directive has been framed by the Dispute Resolution Panel. The role of the transfer pricing officer comes to an end once an order as contemplated under Section 92-CA(4) of the Act has come

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

C\" BENCH: BANGALORE\nBEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA Nos.835 & 836/Bang/2024\n Assessment Years: 2014-15 & 2018-19\nSri Maruthivandith Reddy Mannur\nS-11, Golden Orchid Apartments\nKasturba Road\nBangalore 560 001\nPAN NO: BXXPM1852K\nAPPELLANT\nAppellant by\nRespondent by\nVs.\nDCIT\nCentral circle-1(1)\nBangalore\nRESPONDENT\nShri V. Srinivasan

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

C\" BENCH: BANGALORE\nBEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER\nAND\nSHRI KESHAV DUBEY, JUDICIAL MEMBER\nITA Nos.835 & 836/Bang/2024\n Assessment Years: 2014-15 & 2018-19\nSri Maruthivandith Reddy Mannur\nS-11, Golden Orchid Apartments\nKasturba Road\nBangalore 560 001\nPAN NO: BXXPM1852K\nAPPELLANT\nAppellant by : Shri V. Srinivasan, A.R.\nRespondent by : Ms. Neera Malhotra, D.R.\nDate of Hearing : 06.06.2024\nDate

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

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

C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.345/Bang/2021 Assessment Year: 2016-17 M/s. United Breweries Limited UB City, UB Tower, Level 4 JCIT No.24, Vittal Mallya Road Special Range-7 Vs. Bangalore 560 001 Bangalore PAN NO : AAACU6053C APPELLANT RESPONDENT Assessment Year: 2017-18 M/s. United Breweries Limited

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

C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.345/Bang/2021 Assessment Year: 2016-17 M/s. United Breweries Limited UB City, UB Tower, Level 4 JCIT No.24, Vittal Mallya Road Special Range-7 Vs. Bangalore 560 001 Bangalore PAN NO : AAACU6053C APPELLANT RESPONDENT Assessment Year: 2017-18 M/s. United Breweries Limited

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

C, RMZ Infinity, of Income Tax, Circle 4(1)(1), Old Madras Road, K.R. Puram, Bangalore. Bangalore – 560 016. PAN: AABCE 6565A APPELLANT RESPONDENT Appellant by : Shri Chavali Narayan, CA Respondent by : Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru. Date of hearing : 12.11.2024 Date of Pronouncement : 19.12.2024 O R D E R Per Prashant Maharishi, Vice President 1. This

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 officer of LIBOR plus 400 basis points , no evidence was lead before us that it is not arms’ length, however several judicial precedents were cited to show that in case of such a transaction of capital financing the LIBOR Page 26 of 29 + 200 basis points is appropriate. Therefore, respectfully following those decisions, we direct

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

4 to 4.4 raised by the assessee. 7. The fifth ground relates to the transfer pricing adjustment made by TPO/AO. In the original grounds of appeal that were filed before the Tribunal on 27.07.2021, the five aspects or items of the transfer pricing adjustment were set out in the following manner:- (a) Adjustment for difference in price in Software

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

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

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

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

C, The Deputy Commissioner of 3rd Floor, Old Madras Road Income-tax, Circle 4(1)(1) Benniganahalli, KR Puram Bangalore. vs. Bangalore – 560 016. PAN: AABCE6565A. (Appellant) (Respondent) Appellant by: Ms.Neera Malhotra, CIT-DR Respondent by: Sri.Chavali Narayan & Sri.Keerthinarayan, ARs Date of Date of Hearing : 05.11.2024 Pronouncement: 08.11.2024 O R D E R Per Bench: - Both these appeals

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

C, The Deputy Commissioner of 3rd Floor, Old Madras Road Income-tax, Circle 4(1)(1) Benniganahalli, KR Puram Bangalore. vs. Bangalore – 560 016. PAN: AABCE6565A. (Appellant) (Respondent) Appellant by: Ms.Neera Malhotra, CIT-DR Respondent by: Sri.Chavali Narayan & Sri.Keerthinarayan, ARs Date of Date of Hearing : 05.11.2024 Pronouncement: 08.11.2024 O R D E R Per Bench: - Both these appeals

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

Section 92CA(1) to the Transfer Pricing Officer (TPO) for the\ndetermination of Arm's Length Price (ALP) of the international\ntransactions. The TPO noted that as per the Transfer Pricing (TP)\ndocuments furnished for the Assessment Year 2015-2016, the\nAssessee had entered into the following International Transactions\nwith its AEs:\nInternational Transactions as per 3CEB\nParticulars\nReceived/\nReceivables

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

In the result, the appeal of the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year: 2018-19

Pricing Agreement, the assessee has filed modified ITR u/s 139 r.w.s. 92CD of the Income- tax Act,1961 ['the Act' for short] on 19.10.2020 declaring income of Rs.23,19,09,830/-. The other statutory notices were issued to the assessee. 2.1 The assessee company is engaged in providing software development services including testing, infrastructure support and other related services