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

Transfer Pricing Officer. It is further submitted that the Tribunal failed to note that depreciation cannot be excluded from the cost of tax payer as well as comparables and Rule 10B(1)(e)(iii) of the Income Tax Rules nowhere provides to exclude the depreciation as it will materially affect the adjustments and therefore, the same cannot be excluded. With

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

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 Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.No.2440/Bang/2019 for the assessment year 2015- 16, raising the following substantial questions

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

Transfer Pricing Officer had adopted a method in accordance with Section 92 read with Rule 10B of the Act and therefore

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TEXPORT OVERSEAS PVT LTD

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

transfer pricing order under Section 92CA of the Act to determine arms length price as the assessee had entered into specified domestic transaction and on the 4 ground it was covered under Section 92BA of the Act. Despite objections being filed by the assessee before Dispute Resolution Panel (for short ‘DRP’) directions came to be issued

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S TT STEEL SERVICE INDIA PVT LTD

Bench: V KAMESWAR RAO,S RACHAIAH

Transfer Pricing Adjustment to International Transaction with Associated Enterprises only even when same is contrary to Section 92CA of the Act and when assesse is providing service to both AE and Non-AE's where assesse has not made any bifurcation of profit in book of account as overall profit margin is recorded in books without any data

COMMISSIONER OF INCOME TAX-III vs. M/S YODLEE INFOTECH PVT LTD

The appeal is disposed of

Bench: ALOK ARADHE,M.I.ARUN

Transfer 7 Pricing Officer for examining the issue in the light of the decisions referred to in the order. The Tribunal by placing reliance of this court in M/S TATA ELXSI LTD. granted the benefit of deduction under Section 10B

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

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’) in IT(TP).No.390/Bang/2021 for the assessment year 2009-10. - 3 - NC: 2024:KHC:39764-DB ITA No. 61 of 2024 3. This Court

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

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 by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.No.1692/Bang/2016 for the assessment year 2012-13. 3. This

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

The appeals are dismissed

Bench: B.V.NAGARATHNA,JAYANT PATEL

10B (1)(a) of the Act”? 5 Substantial questions of law in ITA No.470/2013 “1. Whether on the facts and in the circumstances and in law the Tribunal was correct is setting aside the determination of ALP on the International Transaction Payment of Technical Services Fees, directing the Transfer Pricing Officer to reconsider the issue on the most appropriate method

PR COMMISSIONER OF vs. M/S ZYME SOLUTIONS P LTD

Bench: S.SUJATHA,VINEET KOTHARI

SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON’BLE Court AS DEEMED FIT, AND SET ASIDE THE APPELLATE ORDER DATED 22/01/2016 PASSED BY THE ITAT, ‘B’ BENCH, BENGALURU, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEE’S CASE, IN Date

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

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 12.10.2020 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.Nos.160 and 211/Bang/2016 for the assessment year 2011-12, raising the following substantial questions of law: “1. Whether

PR.COMMISSIONER OF INCOME TAX vs. M/S GALAX E SOLUTIONS INDIA PVT LTD

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

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

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 21.10.2020 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.No.184/Bang/2016 for the assessment year 2011-12. 3. This Court, admitted the appeal on 04.7.2023 to consider the following substantial

PR.COMMISSIONER OF INCOME TAX vs. M/S MARLABS INNOVATIONS PVT LTD

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

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

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’) in IT(TP)A.No.430/Bang/2015 and CO.No.160/Bang/2015 for the assessment year 2010-11. 3. This Court, admitted the appeal on 11.07.2022 to consider

PR.COMMISSIONER OF INCOME TAX vs. M/S MARLABS INNOVATIONS PVT LTD

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

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

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’) in - 3 - NC: 2024:KHC:39758-DB ITA No. 162 of 2022 IT(TP)A.No.544/Bang/2015 for the assessment year 2010-11. 3. This

PR.COMMISSIONER OF INCOME TAX vs. M/S GALAX E SOLUTIONS INDIA PVT LTD

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

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

Section 260-A of the Income Tax Act, 1961 (for short ‘the Act’) questioning the correctness and legality of order dated 21.10.2020 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short ‘Appellate Authority’) in IT[TP]A.No.494/Bang/2016 for the assessment year 2011-12, raising the following substantial questions of law: (i) "Whether the Tribunal was right

M/S. TOYOTA KIRLOSKAR MOTOR (P) LTD., vs. THE COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Analysis separately for manufacturing segment and trading segment of the Assessee, but the Tribunal vide para-11 of the same order took a view that Date of Judgment 06-08-2018 I.T.A.No.58/2017 M/s. Toyota Kirloskar Motor (P) Ltd. Vs. The Commissioner of Income Tax & Anr. 5/16 on a comprehensive view of the matter, since the trading activity

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

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

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’) in IT(TP)A.No.242/Bang/2021 for the assessment year 2016-17. 3. This Court, admitted the appeal on 12.12.2023 to consider the following substantial