PRAKASHBAPU PATIL GRAMIN BIGAR SHETI SAHAKARI PATH SANSTHA LTD SANGLI ,SANGLI vs. ACIT, CIRCLE- SANGLI, SANGLI

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

u/s 271D of the Income Tax Act of Rs.1,01,75,465/- in respect of deposits from its members. 2. The Id CIT(A) failed to appreciate that the appellant Society is based in rural area and most of the members are illiterate and agriculturists having transactions below Rs 20000/-. 3. The learned CIT erred in law and on facts

PRAKASHBAPU PATIL GRAMIN BIGAR SHETI SAHAKARI PATH SANSTHA LTD SANGLI ,SANGLI vs. ACIT, CIRCLE- SANGLI , SANGLI

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

u/s 271D of the Income Tax Act of Rs.1,01,75,465/- in respect of deposits from its members. 2. The Id CIT(A) failed to appreciate that the appellant Society is based in rural area and most of the members are illiterate and agriculturists having transactions below Rs 20000/-. 3. The learned CIT erred in law and on facts

TIBCO SOFTWARE B.V.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, (IT), CIRCLE - 2,, PUNE

Appeal is allowed for statistical purposes

Bench: Shri R.S.Syal & Sonjoy Sarma,Jm Assessment Year : 2014-15 Tibco Software B.V. ...... Appellant C/O Tibco Software India P.Ltd. 3 Floor, Binnarius,Deepak Complex, National Games Road, Shastri Nagar, Yerwada, Pune – 411 006. Pan : Aaect3252G V/S. Dcit(It),Circle-2, Pune ……Respondent

penalty proceedings against the Appellant under Section 274 r.w.s 271(1)(c) of the Income-tax Act, 1961.” 3. Briefly, the facts are under : 4. The Appellant TIBCO Software B.V is a non-resident company incorporated in Netherland. The Company is engaged in sale of Software maintenance, consulting and training services in India. The return of income for the Assessment

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (INTERNATIONAL TAXATION), CIRCLE -2,, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

penalty proceedings be overturned. The above grounds are without prejudice to each other.” 5. Briefly, the facts of the case are as under : The appellant TIBCO Software B.V. is a non-resident company incorporated in Netherlands. The company is engaged in sale of Software licences and provision of Software maintenance, Consulting and Training services in India. The return of income

TIBCO SOFTWARE BV,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT), CIRCLE-2,, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravisl.

penalty proceedings be overturned. The above grounds are without prejudice to each other.” 5. Briefly, the facts of the case are as under : The appellant TIBCO Software B.V. is a non-resident company incorporated in Netherlands. The company is engaged in sale of Software licences and provision of Software maintenance, Consulting and Training services in India. The return of income

GRUPO ANTOLIN IRAUSA S.A.,,PUNE vs. DEPUTY DIRECOTR OF INCOME TAX,, PUNE

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryिनधा"रण वष" / Assessment Year: 2010-11 Groupo Antolin Irausa S.A. Vs. Ddit C/O. B-25, Midc, (International Taxation)-1, Ranjangaon, Shirur, Pune Pune 412 220 Pan : Aadcg9626L Appellant Respondent

section 9(1)(vii), defines the term ‘fees for technical services’, as under :- 5 Grupo Antolin Irausa S.A. `For the purposes of this clause, "fees for technical services" means any consideration (including any lump sum consideration) for the rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include

GRUPO ANTOLIN INDIA PRIVATE LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,, PUNE

Appeal is allowed in above terms

Bench: Shri S. S. Godara & Shri Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1207/Pun/2017 िनधा"रण वष" / Assessment Year: 2009-10 Grupo Antolin India Private Vs. Dcit, Circle-1(2), Pune. Limited, B 25, Midc, Ranjangaon, Taluka: Shirur, Pune- 412220. Pan : Aaaca6730G Appellant Respondent Assessee By : Shri J. D. Mistri Revenue By : Shri Piyush Kumar Singh Yadav Date Of Hearing : 22.09.2022 Date Of Pronouncement : 13.10.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2009-10 Arises Against The Cit(A)- 13, Pune’S Order Dated 10.02.2017 Passed In Case No. Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/45/2013-14/606 Involving Proceedings U/S 143(3) R.W.S. 144C(1) Of The Income Tax Act, 1961; In Short “The Act”. Heard Both The Parties. Case File Perused. 2. The Assessee Pleads The Following Substantive Grounds In The Instant Appeal :-

u/s 143(3) r.w.s. 144C(1) of the Income Tax Act, 1961; in short “the Act”. Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds in the instant appeal :- 2 “1:0 Transfer Pricing adjustment of Rs. 3,35,16,306/- while determining the Arm's Length Price ["ALP"] of international transactions in respect