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CONDUENT BUSINESS SERVICES INDIA LLP VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Apr 08, 2022

1. These are cross appeals directed against the assessment order passed under Section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 dated 28.12.2015 in consequence to...

Subject : Transfer pricing adjustment
Legislation Referred To : Section 92C, 143(3), 144C(5)
In Favour Of : Assessee

AITHENT TECHNOLOGIES PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Apr 06, 2022

KPO services are not comparable to software development services and are therefore not comparable.

Subject : Selection of comparables of software development service
Legislation Referred To : Section143(3), 144C, 133(6)
In Favour Of : Assessee

BG EXPLORATION & PRODUCTION INDIA LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
DELHI TRIBUNAL, Mar 31, 2022

1. This appeal filed by the assessee is directed against the order dated 19th January, 2022 passed u/s 143(3) r.w. section144C(13) by the AO for the assessment year...

Legislation Referred To : Section 44C, 143(3), 144C(5)
In Favour Of : Assessee (partly)

BG EXPLORATION & PRODUCTION INDIA LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
DEHRADUN TRIBUNAL, Mar 21, 2022

1. These two appeals are filed by the Assessee against the orders of the Assessing Officer passed u/s 143(3)/144C(13)/254 of the Act for the AYs 2007-08 & 2008-09. 2....

Subject : Transfer pricing adjustment
Legislation Referred To : Section 143(1), 244A, 271(1)(c)
In Favour Of : Assessee (partly)

HEADSTRONG SERVICES INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Mar 17, 2022

1. The present appeal preferred by the assessee for the Assessment Year 2012-13 against the final assessment order dated 25/11/2016 passed u/s 143(3) r/w Section 144C(13)...

Subject : Arm’s length price and related issues
Legislation Referred To : Section 92CA(3), 143(3), 144C(13)
In Favour Of : Assessee (partly)

FMC INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Feb 25, 2022

1. The assessee has filed this appeal challenging the order dated 31.10.2018 passed by the assessing officer for assessment year 2014-15 u/s 143(3) r.w.s. 144C of the Act...

Subject : Selection of comparables of other segment
Legislation Referred To : Section 143(3), 40(a)(i), 35(1)(iv)
In Favour Of : Assessee(partly)

AURIGO SOFTWARE TECHNOLOGIES PRIVATE LIMITED VS INCOME TAX OFFICER
BANGALORE TRIBUNAL, Feb 03, 2022

High turnover is a ground to exclude a company from the list of comparable companies in determining ALP

Subject : Selection of comparables of Software Development Services
Legislation Referred To : Section 143(3), 144C(13)
In Favour Of : Assessee (partly)

SABIC INNOVATIVE PLASTICS INDIA PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
HIGH COURT OF GUJARAT, Jan 24, 2022

Proceedings before the DRP do get circumscribed by the limits of time imposed by Section 153

Subject : Assessment
Legislation Referred To : Section 92CA, 143(3), 144C(13), 153(3), 244A(1)
In Favour Of : Assessee

CENDUIT (INDIA) SERVICES PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Jan 12, 2022

1. This appeal by the assessee is directed against the order of the Assessing Officer, National e-Assessment Centre, Delhi dated 29.03.2021 passed u/s. 143(3) r.w.s....

Subject : Transfer Pricing
Legislation Referred To : Section 40(a)(ii), 234B, 30 to 38
In Favour Of : Assessee

INFOR (BANGALORE) PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Jan 11, 2022

Functionally different companies cannot be selected as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 133(6), 92(1)
In Favour Of : Assessee