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

80 FEET ROAD, KORMANGALA BENGALURU-560 095. ... APPELLANTS (BY SRI. ARAVIND K.V., ADVOCATE ) AND: M/S. IDS SOFTWARE SOLUTIONS INDIA PVT. LTD., 6TH FLOOR, TOWER D DIAMOND DISTRICT AIRPORT ROAD BENGALURU-560 066 PAN: AABCI 2430G. … RESPONDENT (BY SRI. ANKUR PAI D, ADVOCATE FOR SRI. K R VASUDEVAN, ADVOCATE ) +++++ ITA.No.496/2017 - 2 - THIS ITA IS FILED UNDER SECTION

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

80 FEET ROAD, KORAMANGALA BENGALURU - 560095 …APPELLANTS (BY SRI. RAVI RAJ Y V.,ADVOCATE A/W SRI. DILIP M, ADVOCATE) AND: M/S ARISTA NETWORKS INDIA PVT LTD GLOBAL TECHNOLOGY PARK TOWER A AND B 11TH FLOOR, MARATHAHALLI OUTER RING ROAD DEVARABESSANAHALLI, VARTHUR HOBLI BENGALURU - 560103 PAN AAICA9663J …RESPONDENT (BY SMT. TANMAYEE RAJKUMAR.,ADVOCATE) THIS ITA / INCOME TAX APPEAL IS FILED UNDER

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

80,51,42,179 7. The AO had denied the exemption under Section 10AA on the TP pricing adjustment made pursuant to the APA. The AO reasoned that the assessee had declared the TP adjustments in anticipation of such TP adjustments by the TPA and to avoid the rigour of Section 92C(4) of the Act. The AO further observed

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

80 FEET ROAD, KORMANGALA, BENGALURU-560 095 …APPELLANTS (BY SRI. RAVIRAJ Y.V., ADVOCATE A/W SRI. M. DILIP, ADVOCATE) AND: M/S. SWISS RE GLOBAL BUSINESS SOLUTIONS INDIA PVT. LTD., Digitally signed by BHARATHI S Location: HIGH COURT OF KARNATAKA - 2 - NC: 2024:KHC:40053-DB ITA No. 290 of 2022 (PREVIOUSLY KNOWN AS SWISS RE SHARED SERVICES INDIA

COMMISSIONER OF INCOME-TAX vs. M.R.SAMPANGIRAMAIAH

Bench: P.S.DINESH KUMAR,C.M. POONACHA

price component is already paid and what remains to be paid is Rs.49,80,000/-. Vouchsafing the title to property is a predominant obligation of the vendor, vide condition Nos.6, 7 & 8 in Ex.P4, is not disputed before us. Paragraph 2 stipulates that the plaintiff has to pay this amount in two installments: First installment of Rs.34,80

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 is less than eight times the net annual income of the land. (2) Nothing in sub-section (1) shall apply to lands granted under Section 77. -: 80 :- 81. Sections 79-A, 79-B, and 80 not to apply in certain cases.- (1) Nothing in Section 79-A or Section 79-B or Section 80 shall apply

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 is less than eight times the net annual income of the land. (2) Nothing in sub-section (1) shall apply to lands granted under Section 77. -: 80 :- 81. Sections 79-A, 79-B, and 80 not to apply in certain cases.- (1) Nothing in Section 79-A or Section 79-B or Section 80 shall apply

THE PR COMMISSIONER OF INCOME TAX-1 vs. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD

Appeal of the revenue is hereby dismissed

Bench: CHIEF JUSTICE,C M JOSHI

80 FEET ROAD, KORMANGALA BENGALURU - 560 095. …APPELLANTS (BY SRI Y.V. RAVIRAJ, ADVOCATE) AND: 1. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT. LTD., NO.123, HOSUR ROAD INDUSTRIAL LAYOUT KORAMANGALA BENGALURU-560 095 PAN - AAACR 7108R REP. BY ITS MANAGING DIRECTOR. …RESPONDENT Digitally signed by SUMATHY KANNAN Location: High Court of Karnataka

THE PR COMMISSIONER OF INCOME TAX vs. M/S ACUSIS SOFTWARE INDIA

Bench: S.SUJATHA,VINEET KOTHARI

80 FEET ROAD, KORAMANGALA BENGALURU-560095. …APPELLANTS (BY Mr. ARAVIND K.V. ADV.) AND: M/S. ACUSIS SOFTWARE INDIA PVT. LTD., No.17/2, DOLLAR CHAMBER LALBAGH ROAD, BENGALURU-560027 PAN:AADCA2415P. …RESPONDENT (BY Mr. MALLAHARAO K, ADV.) THIS I.T.A IS FILED UNDER SECTION 260-A OF THE INCOME TAX ACT, 1961, PRAYING TO (i) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN

BOSCH AUTOMOTIVE ELECTRONICS INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER INCOME TAX

The appeal is allowed and the Tribunal's

Bench: B M SHYAM PRASAD,T.M.NADAF

80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE - 560034. …RESPONDENTS (BY SRI.Y.V. RAVIRAJ., ADVOCATE) THIS INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, PRAYING TO a) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE; b) ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 16.12.2024 PASSED BY THE TRIBUNAL IN IT(TP)A NO. 1473/BANG/2024, FOR ASSESSMENT

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing adjustment at `25,23,76,521/- in the trading segment. 6. In so far as manufacturing segment is concerned, the learned TPO determined the arms length PLI at 3.45% and accordingly made in adjustment of `6,02,89,351/- for the manufacturing segment

THE DIRECTOR OF INCOME-TAX vs. M/S. INTEL CAPITAL (CAYMAN) CORPORATION

In the result, the appeal fails and is hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 45 of the Act, the cost of acquisition has to be 6 taken as the cost of debentures. It is further submitted that in case of any conflict between scheme / Rules and the provisions of the Act, the provisions of the Act would prevail. It is also submitted that the Bombay High Court in ‘KINGFISHER CAPITAL

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA CO-OPERATIVE MILK PRODUCERS

Appeal is dismissed with costs

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 54 of the Transfer of Property Act, as under: “Sale” defined.—‘‘Sale” is a transfer of ownership in exchange for a price paid or promised or part- paid and part-promised. Sale how made.—Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion

THE COMMISSIONER OF INCOME TAX vs. M/S GARNIWAL EXPORTS (P) LTD

Appeal is allowed

Bench: D.V.SHYLENDRA KUMAR,B.S.INDRAKALA

price of Rs.17,78,155/- received by the assessee by way of transfer of quota opining that the amount represented business income of the assessee; that it cannot be attributed to any export activity as the amount is not by export but received 4 within the country; that Section 80HHC benefit being available only to profits derived from an export

THE PR COMMISSIONER OF INCOME TAX CIT(A) vs. M/S GENISYS INFORMATION

Bench: S.SUJATHA,VINEET KOTHARI

80 Feet Road, Kormangala Bengaluru-560 095. …APPELLANTS (BY Mr.Aravind K.V., ADV.) AND: M/s.Genisys Information Systems (India) Pvt. Ltd., 33-36 & 43-46, Export Promotion Indl. Park, Whitefield, Bengaluru-560 066 PAN:AACCG 3306J …RESPONDENT (BY Mr.Sharath, Adv., for Mr.Chaithanya K.K., ADV.) Date of Judgment 05-07-2018 I.T.A.No.698 /2017 The Pr. Commissioner of Income-tax & Anr. Vs. M/s.Genisys

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

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

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

80 FEET ROAD KORAMANGALA BENGALURU 560095 …APPELLANTS (BY SRI. DILIP M.,ADVOCATE A/W SRI. RAVIRAJ Y V, ADVOCATE) AND: M/S. BOSTIK INDIA PVT LTD NO 124/4 AND 124/4A KACHANAYAKANAHALLI OFF HOSUR ROAD BOMMASANDRA POST ANEKAL TALUK BENGALURU 560099 PAN AABCB 4627N …RESPONDENT (BY SRI. RAVI RAGHAVAN.,ADVOCATE) THIS ITA / INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF THE INCOME

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

80 FEET ROAD, KORAMANGALA BENGALURU-560 095 …APPELLANTS (BY SRI. RAVI RAJ Y V.,ADVOCATE A/W SRI. DILIP M, ADVOCATE) AND: M/S ACI WORLDWIDE SOLUTIONS PVT LTD No.9, SALARPURIA CAMBRIDGE MALL CAMBRIDGE ROAD ULSOOR, BENGALURU - 560 008. …RESPONDENT (BY SRI. NARENDRA KUMAR J JAIN.,ADVOCATE) THIS ITA / INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, PRAYING

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed