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21 results for “transfer pricing”+ Section 55(2)(aa)clear

Sorted by relevance

Delhi91Mumbai46Bangalore21Jaipur19Visakhapatnam17Raipur17Ahmedabad7Chennai7Pune7Hyderabad6Cochin5Surat5Lucknow2Indore2Chandigarh1

Key Topics

Section 153A15Addition to Income14Deduction12Section 10A11Section 143(3)10Section 132(1)10Section 278Section 268Section 271(1)(c)

M/S. ZASH TRADERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(1), BENGALURU

ITA 747/BANG/2023[2020-21]Status: DisposedITAT Bangalore29 Apr 2024AY 2020-21
Section 250Section 55Section 55(2)(aa)Section 55(2)(ac)Section 55(2)(b)

price\nper share of Rs.20.91 [i.e., Rs.1338.40/64] should\nbe taken as the cost of acquisition.\nii In respect of Wipro shares that became property of\nthe assessee on or after 01.04.2001 and before\n01.02.2018, being bonus shares, the cost of\nacquisition should be taken as Nil as per the\nprovisions of Section 55(2)(aa)(B)(iiia

SMT. REDDY SANGEETHA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

ITA 1111/BANG/2022[2015-16]Status: DisposedITAT Bangalore

Showing 1–20 of 21 · Page 1 of 2

8
Section 234B8
Transfer Pricing8
Penalty8
30 Nov 2023
AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R
Section 132(1)Section 139Section 143(3)Section 144Section 153A

pricing adjustment has been made in pursuance of provisions of clause (i) of section 92BA of the Act, which reads as under: “(i) Any expenditure in respect of which payment has been made or is to be made to a person referred in clause (b) of said section 2 of section 40A”. 6.2 Section 92BA of the Act was inserted

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

ITA 1113/BANG/2022[2014-15]Status: DisposedITAT Bangalore30 Nov 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R
Section 132(1)Section 139Section 143(3)Section 144Section 153A

pricing adjustment has been made in pursuance of provisions of clause (i) of section 92BA of the Act, which reads as under: “(i) Any expenditure in respect of which payment has been made or is to be made to a person referred in clause (b) of said section 2 of section 40A”. 6.2 Section 92BA of the Act was inserted

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

ITA 1145/BANG/2022[2010-11]Status: DisposedITAT Bangalore30 Nov 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R
Section 132(1)Section 139Section 143(3)Section 144Section 153A

pricing adjustment has been made in pursuance of provisions of clause (i) of section 92BA of the Act, which reads as under: “(i) Any expenditure in respect of which payment has been made or is to be made to a person referred in clause (b) of said section 2 of section 40A”. 6.2 Section 92BA of the Act was inserted

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

ITA 1146/BANG/2022[2015-16]Status: DisposedITAT Bangalore30 Nov 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R
Section 132(1)Section 139Section 143(3)Section 144Section 153A

pricing adjustment has been made in pursuance of provisions of clause (i) of section 92BA of the Act, which reads as under: “(i) Any expenditure in respect of which payment has been made or is to be made to a person referred in clause (b) of said section 2 of section 40A”. 6.2 Section 92BA of the Act was inserted

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

ITA 1112/BANG/2022[2012-13]Status: DisposedITAT Bangalore30 Nov 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri Nischal B., D.R
Section 132(1)Section 139Section 143(3)Section 144Section 153A

pricing adjustment has been made in pursuance of provisions of clause (i) of section 92BA of the Act, which reads as under: “(i) Any expenditure in respect of which payment has been made or is to be made to a person referred in clause (b) of said section 2 of section 40A”. 6.2 Section 92BA of the Act was inserted

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:

ITA 3430/BANG/2018[2014-15]Status: DisposedITAT Bangalore31 Jul 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 205/BANG/2015[2010-11]Status: DisposedITAT Bangalore31 Jul 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 68/BANG/2015[2010-11]Status: DisposedITAT Bangalore31 Jul 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 559/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jul 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 881/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jul 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 2890/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Jul 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 2301/BANG/2019[2015-16]Status: DisposedITAT Bangalore31 Jul 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

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:

ITA 387/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 Jul 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

55,83,331/- pertains to the year under consideration (A.Y. 2012-13). 6.4 The Assessing Officer (AO) observed that the deduction under Section 80JJAA of the Act is allowed for additional wages paid to new regular workmen employed by an assessee company deriving income or profit from an industrial undertaking engaged in the manufacture or production of articles or things

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

55,83,331/- pertains to the year under consideration (A.Y. 2012-13). 6.4 The Assessing Officer (AO) observed that the deduction under Section 80JJAA of the Act is allowed for additional wages paid to new regular workmen employed by an assessee company deriving income or profit from an industrial undertaking engaged in the manufacture or production of articles or things

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

ITA 1152/BANG/2023[2018-19]Status: DisposedITAT Bangalore28 Feb 2024AY 2018-19

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

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Subramanian .S, JCIT DR
Section 10ASection 10A(9)Section 250

55,534/- and the profit of non 10AA unit is increased by the same amount and the exemption claimed u/s. 10AA was also reduced by the aforesaid figure. The assessing officer also made other additions and assessed the income at Rs. 365,44,91,624/-. Page 4 of 39 3. Aggrieved from the above order, the assessee filed appeal before

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

ITA 257/BANG/2023[2018-19]Status: DisposedITAT Bangalore31 May 2023AY 2018-19

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

For Appellant: Shri Prakash Shridhar Hegde, A.RFor Respondent: Shri Gudimella VP Pavan Kumar, D.R
Section 10ASection 139

55,08,015 consequent to disallowance of deduction under section 10AA of the Act for interest income earned by the Appellant. 4. That the learned CIT(A) has erred in the facts and circumstances of the case by - passing the impugned Order without following the judicial Precedence on this matter. 2. The brief facts of the case are that

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

aas pert the terms and conditions mentioned in the agreement for the property. Further as per statement of Smt. Vishalakshi Devi she received payment from Chandrashekhar S at the behest of Mr. DK Shivkumar. The AO observed that the entire 46 transaction was negotiated and completed by Sri N. Chandrashekhar Shukapuri in the name of Shahshikumar and also the etire

AMRUTHA CONSTRUCTIONS PRIVATE LIMITED,SANJAYANAGAR vs. DCIT CENTRAL CIRCLE 2(2) , BANGALORE

In the result appeal of the Revenue is partly allowed

ITA 978/BANG/2024[2020-21]Status: DisposedITAT Bangalore02 Jun 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Mahesh Kumar L, AdvocateFor Respondent: Smt. Nandini Das, CIT (DR)
Section 132Section 132(4)

2. First, we take up ITA No. 978/Bang/2024, an appeal by the assessee for A.Y. 2020-21. 3. The assessee has raised extensive grounds of appeal running into several pages. The issues raised by the assessee through ground Nos. 1 to 3 of its appeal are general in nature and therefore the same do not requiring any separate adjudication. Hence