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

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

M/S BHUWALKA STEEL INDUSTRIES LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-1(1)(4), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

Transfer Pricing for Specified Domestic Transaction vide Finance Act, 2017. Company is having only specified domestic transactions under section 92BA read with 40A(2)(b). 6. The Learned AO and TPO has erred in determining Arm’s Length Price/ Fair Market Value of the transactions with related parties by applying comparable margins on the whole of Company’s turnover

M/S. BHUWALKA STEEL INDUSTRIES LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

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

Bench: Shri George George K & Shri Laxmi Prasad Sahu

Transfer Pricing for Specified Domestic Transaction vide Finance Act, 2017. Company is having only specified domestic transactions under section 92BA read with 40A(2)(b). 6. The Learned AO and TPO has erred in determining Arm’s Length Price/ Fair Market Value of the transactions with related parties by applying comparable margins on the whole of Company’s turnover

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

2 to section 9(1)(vi) of the Act. The AO noted that the ITAT, Bangalore has held the payments made to GIL towards Adwords program as royalty vide its order dated 23.10.2017. 4. Based on the above information in the case of GIPL, the AO observed that the assessee-GIL has not filed return of income for the respective

GOOGLE IRELAND LIMITED,IRELAND vs. DCIT (IT), JCIT(OSD) (IT) - CIRCLE 1(1), BENGALURU

In the result, the appeals filed by the assessee are allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

2 to section 9(1)(vi) of the Act. The AO noted that the ITAT, Bangalore has held the payments made to GIL towards Adwords program as royalty vide its order dated 23.10.2017. 4. Based on the above information in the case of GIPL, the AO observed that the assessee-GIL has not filed return of income for the respective

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK ,BENGALURU vs. INCOME-TAX OFFICE, WARD-5(2)(1), BENGALURU

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

VAIDYA SRIKANTAPPA SADASHIVAIAH SRIKANTH,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE- 1, , BANGALORE

transfer the land\nto the Board for the purpose for which the land has been acquired.\"\n28. Section 29 deals with payment of compensation, which is extracted as\nunder:\n“29. Compensation: (1) Where any land is acquired by the State Government\nunder this Chapter, the State Government shall pay for such acquisition\ncompensation in accordance with the provisions

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

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 passed under sub-section (3) of Section 92-CA; and (ii) any non-resident not being a company, or any foreign company.? 17. As is manifest from a reading of sub-section (13) of Section 144C of the Act, the AO is not accorded any discretion in the framing of an order of assessment once directions have

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

transfer pricing) – 2 (2) (1) (the learned TPO) and the direction issued by The Dispute Resolution Panel – 2, Bangalore (the DRP) under section 144C (5) of the act wherein the returned income filed by the assessee on 31st of March 2021 declaring total income of ₹ 9

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME TAX OFFICER, WARD- 5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders

THE KARNATAKA STATE CO-OPERATIVE AGRICULTURE AND RURAL DEVELOPMENT BANK,BENGALURU vs. INCOME-TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, the appeals filed by the assessee stands partly\nallowed as indicated herinabove

section\n80P(2)(a)/(d) of the Act.\n2.7 The Ld.AO was thus of the opinion that assessee is into\nBanking business and principle of Mutuality did not satisfy. He\nplaced reliance on the decision of Hon'ble Supreme Court in case\nof Citizens Cooperative Society Ltd., reported in (2017) 397 ITR 1.\n2.8 Aggrieved by the orders