US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

Transfer Pricing Officer are bad in law 1.1 The final order issued by the Assistant Commissioner of Income Tax, Circle 1(1) ('Assessing Officer' or 'AO') is bad on facts and in law, and is in violation of the principles of natural justice

M/S.JOY ALUKKAS INDIA P. LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

transfer pricing additions and secondly as a capital expenditure.” 10. The ground of appeal No.1 is general in nature, does not require any adjudication. 11. The ground of appeal Nos.2 to 8 challenge the action of the TP addition as confirmed by the DRP and also challenging treating the ‘Joy Alukkas Jewellery LLC, Dubai’ as AE of the appellant

M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM

In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

transfer pricing additions and secondly as a capital expenditure.” 10. The ground of appeal No.1 is general in nature, does not require any adjudication. 11. The ground of appeal Nos.2 to 8 challenge the action of the TP addition as confirmed by the DRP and also challenging treating the ‘Joy Alukkas Jewellery LLC, Dubai’ as AE of the appellant

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

Transfer Pricing Officer are bad in law. 2.1 The draft order issued by the Assistant Commissioner of Income Tax Circle 1(1) Trivandrum (`Assessing Officer’ or `AO’) having concurrent jurisdiction over the case, is bad on facts, and is in violation of the principles ;of natural justice

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

Transfer Pricing Officer are bad in law. 2.1 The draft order issued by the Assistant Commissioner of Income Tax Circle 1(1) Trivandrum (`Assessing Officer’ or `AO’) having concurrent jurisdiction over the case, is bad on facts, and is in violation of the principles ;of natural justice

M/S.NAVIGANT BPM (INDIA) P. LTD(EARLIER KNOWN AS REVENUE MED INDIA P. LTD),TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, ground No.4

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

nature. 6.2 Aggrieved, the assessee has raised this issue before the Tribunal. The contentions raised before the Tribunal are as follows:- (i) The assessee is a captive unit earning foreign exchange revenue only from its parent entity; (ii) In order to protect the company from foreign exchange fluctuations, the company has opted for a forward contract and hedges a part

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed\nfor statistical purpose and the stay application is dismissed as\ninfructuous

Transfer Pricing\nOfficer (TPO) for the purpose of determination of ALP in respect of\nthe above international transaction.\n4\nThe TPO vide order dated 09/10/2023 passed u/s. 92CA(3),\nsuggested the TP adjustment in respect of software development\nagreement of Rs. 12,84,50,000/- and also interest on delayed\nreceivables of Rs. 5,97,26,729/- u/s. 92CA

M/S.SPERIDIAN TECHNOLOGIES P. LTD,TRIVANDRUM vs. THE ACIT,CIRCLE-1(1), TRIVANDRUM, TRIVANDRUM

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

Bench: S/Shri Abraham P. George, Am & George George K., Jm

Transfer Pricing study which were functionally comparable to the assessee and qualified all the filters adopted by the TPO: 4 a) Infomile Technologies Ltd. b) E-Zest The Ld. DRP erred in upholding the actions of the TPO/AO. G.1 The TPO/AO erred on law and on facts in arbitrarily accepting the following companies without considering the turnover and size

M/S.ALLIANZ CORNHILL INFORMATION SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, ground Nos

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

Transfer pricing adjustment was reduced to Rs.6,72,554. 2.3 The Assessing Officer on receipt of the DRP’s order dated 12.08.2016, passed the final assessment order u/s 143(3) r.w.s. 144C r.w.s. 92CA of the I.T.Act and issued the demand notice u/s 156 of the Act raising a total demand of Rs.9,38,08,666. 2.4 Aggrieved

THE ACIT, KOLLAM vs. SRI.P.SUNILKUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, KOLLAM vs. SRI.P. SUNIL KUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, CEN-CIRCLE, KOLLAM vs. M/S.SABARI ENTERPRISES P. LTD,, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, CEN-CIRCLE, KOLLAM vs. M/S.SABARI ENTERPRISES P. LTD,, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE CENTRAL CIRCLE, KOLLAM, THE CENTRAL CIRCLE,KOLLAM vs. SRI.P.SUNIL KUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, CEN-CIRCLE, KOLLAM, KOLLAM vs. SRI.P.SUNIL KUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE DCIT, CEN-CIRCLE, KOLLAM, KOLLAM vs. SRI.P>SUNIL KUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE DCIT, CEN-CIRCLE, KOLLAM, KOLLAM vs. SRI.P>SUNIL KUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, CEN-CIRCLE, KOLLAM vs. M/S.SABARI ENTERPRISES P. LTD,, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement

THE ACIT, KOLLAM vs. SRI.P.SUNILKUMAR, KOLLAM

In the result, the appeals of the Revenue as well as the Cross

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

transfer of funds. It was submitted that Shri Ravi Biyala was only a partner of the C.A. firm, who had audited the accounts of M/s. Ajay Iron & Steel Pvt. Ltd. and he had issued an audit report in Form No. 3CA and its annexure in From No. 3CD. It was submitted that Shri Ravi Biyala also retracted his statement