PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer, the Assessee Company within 30 days can either accept the said Draft Order or file its objections before the Dispute Resolution Panel (DRP) and the Assessing Officer as per Section 144-C of the Act. The said Dispute Resolution Panel comprises of a Collegium of three Principal Commissioners or Commissioners of Income Tax constituted by the Board

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Transfer Pricing Officer” means a Joint Commissioner or Deputy 23 Commissioner or Assistant Commissioner authorized by the Board to perform all or any of the functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons. 144C. (1) xxxxx (2) xxxxx (b) file his objections, if any, to such variation with

THE PR. COMMISSIONER OF INCOME TAX CIT(A) vs. M/S IDS SOFTWARE SOLUTIONS INDIA PVT LTD

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

Transfer Pricing Adjustments results in multi layer litigation at multiple Fora. After the lengthy process of the same, the matter reaches the Tribunal which also takes its own time to decide such appeals. In the course of this dispute resolution, much has already been lost in the form of time, man-hours and money, besides giving an adverse picture

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S CONTIENENTAL AUTOMOTIVE COMPONENTS (INDIA) PVT LTD.,

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri.Sanmathi.E.I., for appellants/Revenue and learned counsel Smt.Tanmayee Rajkumar for respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 17.08.2023 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority

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

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri.Raviraj Y.V, along with learned counsel Sri Dilip M, for appellants/Revenue and learned counsel Smt.Tanmayee Rajkumar, for the respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 5.10.2021 passed by the Income Tax Appellate

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

JUSTICE. THIS I.T.A. COMING ON FOR HEARING, THIS DAY, ALOK ARADHE J., DELIVERED THE FOLLOWING: JUDGMENT This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the revenue. The subject matter of the appeal pertains to the Assessment year 2010-11. The appeal was admitted

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

transfer pricing adjustment actually was not determinative of the refund inasmuch as the tax 8 amount was paid based on book profit, as provided u/s 115JB; the entitlement of the assessee for interest u/s 244A(1A) is intended to bring parity in the converse situation where the Revenue levies interest on delayed payment of taxes as provided u/s 234B

THE PR COMMISSIONER OF INCOME TAX vs. M/S SWISS RE GLOBAL BUSINESS SOLUTIONS INDIA PVT LTD

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri. Raviraj.Y.V. along with Sri. M.Dilip, learned counsel for the appellants/Revenue and Sri. Nageswar Rao, learned counsel for the respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short ‘the Act’) questioning the correctness and legality of order dated 30.12.2021 passed by the Income

THE PR. COMMISSIONER OF INCOME TAX vs. M/S. CONTINU SERVE SOFTECH INDIA PVT. LTD.,

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri. Dilip.M., along with Sri. Raviraj.Y.V., learned counsel for the appellants/Revenue. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 23.09.2022 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority

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

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 by the revenue. The subject matter of the appeal pertains to the Assessment Year 2010-11. The appeal was admitted

PR COMMISSIONER OF INCOME TAX - 2 vs. M/S PARAMETRICS TECHNOLOGY PVT LTD

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri.Sanmathi.E.I., for appellants/Revenue and learned counsel Smt.Tanmayee Rajkumar for respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 13.05.2020 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

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

Bench: ALOK ARADHE,R. NATARAJ

JUSTICE NATARAJ RANGASWAMY I.T.A. NO.680 OF 2015 BETWEEN: 1. THE PR. COMMISSIONER OF INCOME TAX C.R. BUILDING, QUEENS ROAD BANGALORE-560001. 2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-11(1), NEW DELHI. ... APPELLANTS (BY SRI. T.N.C. SRIDHAR, ADV.,) AND: M/S. EDS ELECTRONICS DATA SYSTEMS INDIA PVT. LTD., [NOW MERGED WITH MPHASIS LIMITED] ABACUS SQUARE, 6TH FLOOR BLOCK-A, BAGMANE

THE COMMISSIONER OF INCOME TAX vs. M/S FIRST ADVANTAGE OFFSHORE SERVICES PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

JUSTICE AND EQUITY. THIS I.T.A. COMING ON FOR HEARING, THIS DAY S. SUJATHA J. DELIVERED THE FOLLOWING:- JUDGMENT Mr. K.V. Aravind, Adv. for Appellants- Revenue Mr. Sankeerth Vittal, Adv. for Mr. Arun Srikumar, Adv. for Respondent - Assessee 1. The Appellants-Revenue have filed this appeal u/s.260A of the Income Tax Act, 1961, raising purportedly certain substantial questions of law arising

THE PR. COMMISSIONER OF INCOME TAX vs. MARLABS INNOVATIONS PVT LTD

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

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

Transfer Pricing Officer in TPO order whereby the said authority has categorically held that functions of said comparable companies are similar to that of assessee in respect of nature of filed they are involved"? 3. "Whether on the facts and in the circumstances of the case, the Tribunal is right in law in taking different stands on adjustments to comparables

M/S SSJV PROJECTS PRIVATE LIMITED vs. M/S ALLAHABAD BANK

In the result, the writ appeals are disposed in

Bench: B.V.NAGARATHNA,R. NATARAJ

price -: 37 :- for removal of minerals and hence, did not attract liability to pay purchase tax. (c) In Embassy Property Developments Private Limited vs. State of Karnataka, [2019 SCC Online SC 1542], (Embassy Property), one of the preliminary questions that arose was whether the High Court ought to interfere under Article 226/227 of the Constitution, with an Order passed

SRI U M RAMESH RAO vs. UNION BANK OF INDIA

In the result, the writ appeals are disposed in

Bench: B.V.NAGARATHNA,R. NATARAJ

price -: 37 :- for removal of minerals and hence, did not attract liability to pay purchase tax. (c) In Embassy Property Developments Private Limited vs. State of Karnataka, [2019 SCC Online SC 1542], (Embassy Property), one of the preliminary questions that arose was whether the High Court ought to interfere under Article 226/227 of the Constitution, with an Order passed

SUNDAR PUJARI vs. THE GOVERNMENT OF KARNATAKA

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

Bench: ARAVIND KUMAR,B.A.PATIL

JUSTICE S.G.PANDIT) Heard the learned counsel Sri.Sanmathi.E.I., for appellants/Revenue and learned counsel Sri.Raghuram Cadambi for respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated - 3 - NC: 2024:KHC:39700-DB ITA No. 220 of 2020 29.11.2019 passed

THE PR COMMISSIONER OF INCOME TAX vs. M/S ACI WORLDWIDE SOLUTIONS PVT LTD

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

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

JUSTICE S.G.PANDIT) Heard the learned counsel Sri Raviraj Y.V, along with learned counsel Sri Dilip M, for appellants/Revenue and learned counsel Sri Narendra Kumar J Jain, learned counsel for the respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated