THE PR. COMMISSIONER OF INCOME TAX vs. M/S. ACER INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

TP] A.No. 1179/Bang/2012 for A.Y. 2007-08 in The Asst. Commissioner of Income Tax, Circle 11(1), Bangalore –v- M/s Acer India Pvt. Ltd., Bangalore. 2. Learned Tribunal following its own order for the preceding assessment year in the case of Date of Judgment 25-06-2018, ITA No.356/2016 The Pr. Commissioner of Income-tax CIT[A] & another

THE COMMISSIONER OF INCOME-TAX vs. TEXAS INSTRUMENTS INDIA PVT LTD

The appeals are dismissed

Bench: SATISH CHANDRA SHARMA,SURAJ GOVINDARAJ

TP)A No.149/Bang/2014 for the assessment year 2008-2009 and seeking to confirm the order passed by the Joint Commissioner of Income Tax, LTU, Bangalore. 10. The above appeals were admitted on 8.10.2020 and the following substantial questions of law were formulated: “1. Whether, on the facts and in the circumstances of the case, the Tribunal is right

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

TP provisions cannot be applied in the present case because the parameters specified u/s 92A (2) of the I.T. Act are not attracted, where reliance was placed on the tribunal order rendered in the case of Page Industries Limited vs. DCIT in ITA No. 163/Bang/2015, copy of which is available on pages 15 to 38 of the paper book

PR COMMISSIONER OF INCOME TAX-5 vs. M/S PAGE INDUSTRIES LTD

In the result, the appeal fails and is hereby dismissed

Bench: ALOK ARADHE,R. NATARAJ

TP)A No.163/BANG/2015 FOR A.Y.2010-11 VIDE ANNEXURE-A, & GRANT SUCH OTHER RELIEF AS DEEMED FIT, IN THE INTEREST OF JUSTICE. THIS ITA COMING ON FOR HEARING, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: JUDGMENT This appeal under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed

PR COMMISSIONER OF INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

In the result, we do not find any merit in this appeal

Bench: ALOK ARADHE,R. NATARAJ

TP)A No.1512/Bang/2010 dated 26.06.2015 even when assessing authority rightly held that payment for 3 purchase of software was in the nature of 'royalty' in terms of Explanation 2 to Section 9 (1)(vi) of the Act? (2) Whether on the facts and in the circumstances of the case, the Tribunal is right in setting aside disallowance made under Section

PRINCIPAL COMMISSIONER OF INCOME TAX - 5 vs. M/S NCR CORPORATION (INDIA) PVT LTD

Appeal is dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

TP)A. No.1090/Bang/2012 (Annexure-A) with the following substantial question of law: "Whether on the facts and circumstances of the case and in law, the Tribunal was right in allowing substantial expenditure of Rs.3.51 crores incurred on renovation of the office building as revenue expenditure without appreciating that this expenditure is of such nature, which fits into expenditure mentioned

APPLE INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

TP)A No. 242/Bang/2016 passed by the ITAT has been admitted to consider the following questions of law: 1. Whether, on the facts and circumstances of the case and in law, the Tribunal is right in allowing the provisions for warranty even though the disallowance had been relying on the decision of Apex court in the case of Rotark Controls

PR COMMISSIONER OF vs. M/S LUWA INDIA PRIVATE LIMITED

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

TP)A No.16/Bang/2015. It is also pointed out that the aforesaid order was challenged by the revenue in ITA No.25/2017 and a Bench of this Court by a judgment dated 27.08.2018 passed in ITA No.25/2017 has dismissed the appeal preferred by the revenue. It is also submitted that the issue that the Transfer Pricing Officer can only determine the Arms

THE PR COMMISSIONER OF INCOME TAX vs. M/S MPHASIS LTD

The appeal is dismissed accordingly

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

TP)A. No.242/Bang/2014 for the assessment year 2009-10. 2. The facts of the case reveal that the respondent – assessee is a company duly incorporated under the Companies Act, 1956 and is engaged in the business of providing software development services to its group of companies. It is a subsidiary of Mphasis group. The return of income for the assessment

SMT. PUNEETHA @ PUNEETHA B. A. vs. SRI. D. RAVI

The appeal is dismissed accordingly

Bench: R DEVDAS

TP)A. No.242/Bang/2014 for the assessment year 2009-10. 2. The facts of the case reveal that the respondent – assessee is a company duly incorporated under the Companies Act, 1956 and is engaged in the business of providing software development services to its group of companies. It is a subsidiary of Mphasis group. The return of income for the assessment

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

TP)A No.461/Bang/2016 (Annexure F), to the extent questioned herein; in the interest of justice & equity etc. This I.T.A. having been heard and reserved on 12-07-2018, coming on for Pronouncement of Judgment, this day, Dr Vineet Kothari, J, delivered the following: J U D G M E N T Mr. Percy Pardiwala. Sr. Counsel a/w Mrs. Tanmayee Rajkumar

THE COMMISSIONER OF INCOME TAX vs. M/S FOSROC CHEMICALS INDIA PVT LTD

The appeals are dismissed

Bench: B.V.NAGARATHNA,JAYANT PATEL

TP)A NO.1256/BANG/2011 DATED 05/04/13 AND CONFIRM THE ORDER OF THE APPELLATE COMMISSIONER CONFIRMING THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, LTU, BANGALORE. THESE APPEALS COMING ON FOR ADMISSION THIS DAY, JAYANT PATEL J., DELIVERED THE FOLLOWING: 4 JUDGMENT The appellants-Revenue have preferred the present appeals by raising the following substantial questions

THE PR COMMISSIONER OF INCOME TAX vs. ADC INDIA COMMUNICATIONS LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

TP)A.No.79/Bang/2016 for the assessment year 2011- 12, raising the following substantial questions of law: - 3 - NC: 2024:KHC:41506-DB ITA No. 494 of 2022 “1. Whether on the facts and in the circumstances of the case, the Tribunal is right in law include/exclude comparable’s namely, M/s. Dynalog (India) Ltd & M/s. Spanco Limited on the ground that

M/S ALTAIR ENGINEERING INDIA PVT LTD vs. THE DEPUTY COMMISSIONER

Bench: S.SUJATHA,VINEET KOTHARI

TP] A No.290/Bang/2011 dated 11.10.2011 relating to the Assessment Year 2007-08. 2. This Appeal has been admitted on 12.06.2012 to consider the following substantial questions of law as framed by the Assessee in the Memorandum of Appeal: “1. Whether in law, the Tribunal was justified in approving the ALP determined by the TPO and approved by the DRP without

THE PR COMMISSIONER OF INCOME TAX vs. M/S CITRIX R AND D INDIA PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

TP)A.No.592/Bang/2016 for the assessment year 2011-12. 3. This Court, admitted the appeal on 24.10.2019 to consider the following substantial questions of law: "i. Whether on the facts and circumstances of the case, the Tribunal is right in law in holding that M/s.R.S.Software Pvt. Ltd., and M/s.Acropetal Technologies Ltd., cannot be taken as comparable