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2020 (8) TMI 10 - ITAT MUMBAI The appeal was allowed, directing the AO to recompute the margin of remaining comparables for transfer pricing adjustment and delete the disallowance under section 14A of the Income Tax Act. The Tribunal excluded certain companies from comparables, citing errors in the TPO's approach and lack of consideration for functional differences. The disallowance under section 14A was deleted as the AO failed to record satisfaction as per Rule 8D. The procedural delay due to COVID-19 was acknowledged, with the appeal decided in favor of the assessee.
2020 (6) TMI 834 - ITAT BANGALORE The Tribunal partly allowed the appeal for statistical purposes. It directed the exclusion of certain comparables in both the software development services and ITES segments based on functional dissimilarity and turnover criteria. The Tribunal remitted some issues to the DRP and TPO for fresh adjudication, including the exclusion of specific companies and the negative working capital adjustments. The matter of disallowance of software expenses under Section 40(a)(ia) and the addition of the provision for loyalty bonus under Section 115JB were restored to the Assessing Officer for further verification.
2019 (12) TMI 1318 - ITAT COCHIN The Tribunal partially allowed both the assessee's and Revenue's appeals. Key determinations included upholding the non-inclusion of prior period income in current margins, allowing the assessee's deduction under section 10A, and directing the AO to exclude foreign exchange fluctuations from operating expenses. Several companies were excluded as comparables due to functional dissimilarities and lack of segmental data. The Tribunal remitted certain issues back to the AO for further examination, particularly concerning the application of filters and allowance of working capital adjustments. Penalty proceedings under section 271(1)(c) were not specifically addressed.
2019 (8) TMI 1630 - ITAT PUNE The Tribunal excluded Bodhtree Consulting Ltd., KALS Information Technology Systems Ltd., Infosys Technologies Ltd., Accentia Technologies Ltd., Cosmic Global Limited, and Eclerx Services Limited from the list of comparables for Software Development and ITes Services. The Tribunal set aside the previous order and instructed the AO/TPO to reassess the Arm's Length Price (ALP) for these services, granting the assessee a fair hearing in line with natural justice principles. The appeal was allowed for statistical purposes.
2019 (6) TMI 1489 - ITAT MUMBAI The appeals were decided as follows: The CIT(A)'s decision allowing depreciation on leased assets was upheld. Allsec Technologies Ltd. was included as a comparable, while E-clerx Services Ltd. was excluded. Apitco Ltd. and ICRA Management Consulting Services Ltd. were excluded from the final set of comparables for benchmarking Business Support Services (BSS), and the TPO was directed to recompute the transfer pricing adjustment accordingly. Other grounds raised by the assessee were dismissed as not pressed due to adjustments in the comparables list.
2018 (9) TMI 1392 - DELHI HIGH COURT The High Court upheld the Tribunal's decision regarding the exclusion/inclusion of comparables for benchmarking in the case of the respondent-assessee for Assessment Year 2011-12. The Court found consistency with the previous year's decision and dismissed the Revenue's appeal, stating no substantial question of law arose for consideration. The appeal was dismissed without any order as to costs.
2018 (4) TMI 1755 - ITAT BANGALORE The appeals were partly allowed, directing the Assessing Officer (AO) to verify and correct the Tax Deducted at Source (TDS) and Foreign Tax Credit (FTC) claims. Adjustments were made to the Arm's Length Price (ALP) determinations for Software Development Services (SWD) and Information Technology Enabled Services (ITES) for the relevant assessment years based on a revised list of comparables, ultimately leading to the deletion of the Transfer Pricing (TP) adjustments.
2017 (8) TMI 1050 - CESTAT MUMBAI The Tribunal allowed the appeal filed by M/s. Yamazaki Mazak India Pvt Ltd, confirming that the services provided by the appellant qualified as export of service. Consequently, the demand of service tax and imposition of penalties under Section 77 and 78 of the Finance Act, 1994 were set aside. The Tribunal's decision was pronounced on 12.7.17.
TPA - ALP determination - AO/TPO directed to adopt CUP method for the medical transcription services and TNMM for the software development services - AT
2016 (6) TMI 1259 - ITAT DELHI The Tribunal directed the AO to compute the arm's length price (ALP) in accordance with the Tribunal's observations for the inclusion/exclusion of comparables. The appeal was partly allowed, emphasizing the importance of functional comparability, proper segmental reporting, and a balanced approach in selecting comparables. The Tribunal's decision highlights the necessity of a meticulous and fair benchmarking analysis in transfer pricing cases.
2016 (5) TMI 1404 - ITAT PUNE The Tribunal partly allowed the assessee's appeal by directing the exclusion of certain comparables and correction of margins, resulting in no addition to the assessee's income on account of arm's length price adjustment. The Revenue's appeal was dismissed.
2016 (4) TMI 356 - ITAT DELHI The Tribunal dismissed both the Revenue's appeal and the assessee's cross-objection. The exclusion of Mold-Tek Technologies Ltd. as a comparable was upheld due to abnormal profits and involvement in mergers and acquisitions. The Tribunal stressed the need for a consistent approach and statutory safeguards in transfer pricing adjustments.
2016 (3) TMI 356 - ITAT BANGALORE The Tribunal partly allowed the assessee's appeal in the case involving transfer pricing and corporate tax matters. The Tribunal directed the re-computation of the Arm's Length Price (ALP) by excluding certain comparables and including foreign exchange gains in the operating profit. Additionally, the Tribunal upheld the reduction of travel expenses from both export turnover and total turnover for computing the deduction under Section 10A. The revenue's appeal was dismissed, affirming the CIT(A)'s directions on the tax deduction computation.
2015 (1) TMI 917 - ITAT MUMBAI The Tribunal partly allowed the assessee's appeal, directing fresh analysis on transfer pricing comparables and software license expenses. The matter of interest income mismatch was remanded for reconciliation. The initiation of penalty proceedings was deemed premature. The department's appeal challenging ITES comparables, loss-making comparables, and working capital adjustment was dismissed, affirming the DRP's decision.
2013 (11) TMI 216 - ITAT BANGALORE The Tribunal partly allowed both the assessee's and revenue's appeals. It directed specific inclusions/exclusions of comparables and adjustments to working capital. The Tribunal upheld the CIT(A)'s decisions on corporate tax and section 10A computation. The levy of interest under section 234B was deemed consequential and mandatory, with the AO directed to recompute the interest accordingly.
2011 (4) TMI 870 - ITAT, Chandigarh The Tribunal partly allowed the assessee's appeal for the assessment year 2005-06 and fully allowed the appeals for 2006-07 and 2007-08. The Revenue's appeal and the assessee's cross objections for 2005-06 were dismissed. The Tribunal confirmed the assessee's eligibility for section 10B exemption, corrected profit estimation under section 10B(7) and section 80IA(10), adjusted disallowance under section 14A, and dismissed the addition under section 69C.
Clarification on changes proposed in the Finance Bill, 2006 The Finance Bill, 2006 introduces significant changes to the service tax regime, including an increase in the service tax rate from 10% to 12%. New taxable services are specified, and the scope of existing services is clarified. Key amendments include the inclusion of services provided by unincorporated associations to their members as taxable, expansion of service provider definitions from 'commercial concern' to 'person', and the introduction of reverse charge mechanisms for services provided from outside India. Certain exemptions are withdrawn, while new exemptions are introduced. Procedural changes in the Service Tax Rules, 1994 are also outlined.
2023 (7) TMI 897 - ITAT BANGALORE The Tribunal partly allowed the appeal, directing fresh adjudication on the inclusion of Universal Print Systems Limited (UPS) and BNR Udyog Ltd. as comparables for Transfer Pricing purposes. It also instructed verification of the short credit of taxes paid and the consequential levy of interest under Section 234A. UPS may be excluded if adjustments cannot be accurately made, considering functional dissimilarities, while BNR Udyog Ltd. should be excluded if it fails the functionality test due to differences in services provided compared to the assessee.
2022 (2) TMI 177 - ITAT MUMBAI The Tribunal allowed the deduction of Equity Stock Options (ESOP) expenditure under section 37(1) of the Income Tax Act, rejecting the disallowance by the Assessing Officer and Dispute Resolution Panel. The Tribunal remanded the quantification of deduction under section 10A back to the AO for verification, directed the allowance of Long Term Capital Loss, instructed the AO to dispose of the rectification application, and ordered the correct computation of interest under sections 234B, 234C, and 234D. Additionally, the Tribunal admitted an additional ground of appeal regarding deduction for Education Cess and Higher and Secondary Education Cess and directed a transfer pricing adjustment by excluding a comparable company.
2021 (3) TMI 928 - ITAT, BANGALORE The Tribunal partly allowed both the revenue and assessee's appeals, remanding several issues back to the AO/TPO for reconsideration. The decision stressed the significance of functional comparability and consistent application of filters in Transfer Pricing analysis, aligning with precedents set by higher judicial authorities. Notable outcomes included the allowance of software expenses under section 40(a)(i) and directives on MAT credit, TDS credits, working capital adjustments, and deductions under section 10A without setting off business losses. The decision underscored the need for meticulous analysis and adherence to legal standards in resolving complex tax matters.
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