M/S SOBHA CITY ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(2), BANGALORE

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

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year : 2014-15

transfer pricing adjustment is liable to be deleted. When it was pointed out that ITA No.2936/Bang/20180 M/s. Sobha City, Bangalore Page 6 of 16 the coordinate bench has restored the issue to the file of the A.O. for examining the payments in terms of section 40A(2) of the Act, the Ld. A.R. submitted that this issue may be restored

M/S. CAUVERY AQUA PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(1)(1), BENGALURU

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

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2021/Bang/2019 Assessment Year: 2015-16

transfer pricing adjustment is liable to be deleted. When it was pointed out that the coordinate bench has restored the issue to the file of the A.O. for examining the payments in terms of section 40A(2) of the Act, the Ld. A.R. submitted that this issue may be restored to the file of the A.O. for examining

TIMKEN ENGINEERING & RESEARCH INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

DCIT, BANGALORE vs. M/S TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

DCIT vs. M/S TIMKEN ENGINEERING AND RESEARCH PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

M/S TIMKEN ENGINEERING & RESEARCH INDIA P. LTD. vs. DCIT,

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

M/S. TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

section 234C of the Act of INR 64,731. [corresponding to ground 19] 23. That the Appellant craves leave to add to and/or to alter, amend, rescind, modify thegrounds herein above or produce further documents before or at the time of hearing ofthis Appeal. [corresponding to ground20] ADDITIONAL GROUNDS OF APPEAL Transfer Pricing Related: 24. The learned AO / TPO erred

MRS. SUVINA KRUPAL,SOMWARPET vs. ITO, MADIKERI

In the result appeal stands allowed as indicated hereinabove

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

5A, Pritech SEZ, Varthur Hobli, Outer Ring Road, Bellandur, Bangalore-560 037. PAN : AACCC 1734 G APPELLANT RESPONDENT Page 2 of 28 ITA No.337 & 204/Bang/2014 Appellant by : Shri L Barath, C.A Respondent by : Shri Manjeet Singh, Addl. CIT – DR Date of Hearing : 17-06-2020 Date of Pronouncement : 14-08-2020 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present cross appeals

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

section 142[1], either the Assessing Officer or the Prescribed Income- tax Authority, as the case may be, if, it is considered necessary or expedient to ensure that an assessee has not understated the income or has not computed excessive loss or has not underpaid tax in any manner, shall serve on the assessee a notice for attendance or production

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer 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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer 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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer 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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer 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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

transfer 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

FNF BUSINESS PROCESS OUTSOURCING,BANGALORE vs. DCIT CR 3(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Shri Laliet Kumar

section 234D of the Act is consequential in nature. The appellant craves leave to add, alter, rescind and modify the grounds provided herein above or produce further documents, facts and evidence before or during the course of hearing of this appeal. For the above and any other grounds which may be raised at the time of hearing, it is prayed

NALAPAD PROPERTIES ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-2(3) , BANGALORE

5A) of the Act applicable with effect from assessment year 2017-18 and onwards. 18.The appellant submits that on parity of the reasons mentioned in the above judicial decisions relating to deemed transfer of capital asset in the scheme of JDA, the income arising from transfer of the Non Capital asset being Stock-in-Trade is also chargeable

DCIT vs. M/S PMC SIERRA INDIA PVT. LTD.,, BANGALORE

In the result, the revenue’s appeal as well as C

Bench: Shri Abraham P George & Shri Vijay Pal Rao

5A Block, 2nd Floor, Pritechpark, Tax, Circle 12(2), Bangalore. SEZ, Bellandur, Bangalore-560 103 PAN AADCP 6802F Appellant Respondent. C.O.No.173/Bang/2015 I.T(T.P) A. No.882/Bang/2013 (Assessment Year : 2008-09) (By Assessee) Appellant/C.O. By : Shri T.Suryanarayana, Advocate. Respondent By : Dr.P.K. Srihari, Addl. CIT (D.R.) Date of Hearing : 5.7.2016. Date of Pronouncement : 26.8.2016. O R D E R Per Shri Vijay

PMC - SIERRA INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

5A Block, Pritech Circle 12(2), Bangalore. Park, SEZ, ORR, Bellandur, Bangalore-560 103 PAN AADBP 6803 F Appellant Respondent. Appellant By : Shri T. Suryanarayana, Advocate. Respondent By : Smt. Swapna Das, JCIT (DR) (ITAT)-2, Bengaluru. Date of Hearing : 07.03.2017. Date of Pronouncement : 13.04.2017. O R D E R Per Shri Vijay Pal Rao, J.M. : This appeal by the assessee