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

In the result appeal filed by the assessee is partly allowed

Transfer Pricing) 2 (2) (1)\nBangalore (the learned TPO) on 28th of January 2022 and the direction\nissued by The Dispute Resolution Panel 2, Bangalore (the learned\ndispute resolution panel/the DRP) under Section 144C (5) of the act\nwherein the total income of the assessee as per return of income filed on\n30 November 2019 of ₹ 7,901,553,920

EMC SOFTWARE AND SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 2, BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes as per the terms mentioned above

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

transferred its Product Engineering Services business to L&T Technology Services Ltd. and wound up its subsidiary GDA Technologies Inc. Detailed submissions are placed at pages 50-59 and 437-451 of the paperbook. It is submitted that this company is consistently excluded from the final list of comparables in cases of assessee’s placed similar to the Appellant. Reliance

M/S. TECHNICOLOR INDIA PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2010-11

transfer pricing adjustment of 1NR42,76,899 on account of provision of market support services, alleging the same to be not at arm's length in terms of the provisions of section 920

UXC INDIA IT SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

transfer pricing adjustment of INR1,14,70,507 in respect of international transaction pertaining to receipt of intra-group services from associated enterprises. 11. That on the facts and circumstances of the case and in law, the AO/DRP/TPO have erred in alleging, inter alia, that the Appellant had failed to establish the receipt of services, justification of the costs incurred

MOHAMMED ABDUL NAJEEB,GULBARGA, KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELLARY

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

transfer of\njurisdiction from Gulbarga regular\njurisdiction, without complying to the\nmandatory requirements of provisions of\nSection 127 of the Act. In this regard, the\nappellant places reliance on the following\njudicial precedents:\na) SAHARA HOSPITAL LTD\nV/S CIT (2012) 211\nTAXMANN 299 (BOM)\nb) AJANTA INDUSTRIES V/S\nCBDT (1976) 102 ITR 281\n(SC)\nc) MUKUTLA LALITA V/S\nCIT

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S ANUSHKA ESTATES, BANGALORE

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. ANUSHKA REALTY INC, BENGALURU

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. ANUSHKA REALTY INC, BENGALURU

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. ANUSHKA REALTY INC, BENGALURU

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S ANUSHKA ESTATES, BENGALURU

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. ANUSHKA REALTY INC, BENGALURU

In the result, the appeal of the revenue in ITA

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

920 2017-18 4,68,33,43,616 1,38,39,28,039 68.14 94,30,08,565 35,31,

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

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

920/- [ Rs.55,56,54,057/- (revenue expenditure) + Rs. 8,11,20,826/- (capital expenditure)] which amounts to claim of double deduction & the same is accepted by the assessee on the I. Tax web portal. It is worthwhile here to note that once the Auditor uploads the audit report on the I. Tax Web Portal from his professional ID, it automatically

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S ANUSHKA ESTATES, BENGALURU

In the result, all the seven appeals filed by the revenue are\ndismissed

920\n2017-18 4,68,33,43,616 1,38,39,28,039 68.14\n94,30,08,565\n35,31,62,411 58,98,46,155 48,22,26,864\n2018

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

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

section 132(1)(a)(b)(c) of\nthe Act on this point we are in agreement with the arguments advanced by the\nlearned DR that we do not have power to decide the validity of search.\nTherefore this issue is rejected. Assessee has challenged before us regarding\ndepreciation claimed on the goodwill arising out of the business transfer as\nper

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2) , BENGALURU

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

section 132(1)(a)(b)(c) of\nthe Act on this point we are in agreement with the arguments advanced by the\nlearned DR that we do not have power to decide the validity of search.\nTherefore this issue is rejected. Assessee has challenged before us regarding\ndepreciation claimed on the goodwill arising out of the business transfer as\nper

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

section 132(1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

section 132(1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer

M/S. BARBEQUE NATION HOSPITALITY LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

section 132(1)(a)(b)(c) of the Act on this point we are in agreement with the arguments advanced by the learned DR that we do not have power to decide the validity of search. Therefore this issue is rejected. Assessee has challenged before us regarding depreciation claimed on the goodwill arising out of the business transfer