submitted that clubbing / aggregation of non-international
transaction with international transaction based on economic
analysis carried out for international transaction itself is
against TP regulations ... basis.
the said international transaction should necessarily be
bundled with other international transactions and the net
profit margin of all the international transactions should
Dell International Services India ... vs Joint Commissioner Of Income Tax, Ltu, ... on 18 March, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL
BANGALORE BENCHES ... Bang/2014 : Asst.Year 2009-2010
M/s.Dell International Services The Joint Commissioner of
India Private Limited V. Income-tax, LTU
(for the merged
Dell International Services India ... vs Additional Commissioner Of Income Tax ... on 20 January, 2023
IN THE INCOME TAX APPELLATE TRIBUNAL
BANGALORE BENCHES ... 2835/Bang/2017 : Asst.Year 2013-2014
M/s.Dell International Services The Additional Commissioner
India Private Limited v. of Income-tax (LTU)
Divyashree Greens
Dell International Services India ... vs Additional Commissioner Of Income Tax ... on 7 August, 2023
IT(TP)A No.2846/Bang/2017
M/s. Dell International ... 2846/Bang/2017
Assessment Year: 2013-14
M/s. Dell International Services
India Pvt. Ltd.
12/1, 12/2A, 13/1A, Divyashree Addl. CIT
Gardens
Bang/2015
Assessment year : 2010-11
M/s.Dell International Services Vs. The Joint Commissioner of
India Private Limited, Income Tax, LTU,
(for the merged ... Assessment year : 2010-11
The Joint Commissioner of Vs. M/s.Dell International Services
Income Tax, LTU, India Private Limited,
Bangalore. (for the merged entity
also rely on the judgment of AAR in the case of Dell International
Services (P.) Ltd. (supra). It was held by the AAR that
case of Isro
Satellite Centre 307 ITR 59 and Dell International Services
(India) P. Ltd. 305 ITR 37, we are of the view that
reliance upon the ISRO Satellite Centre vs. DIT 307
ITR 59; Dell International Services India ... ruling in the
in the case of Dell case of Dell is applicable to
International Service India this case. in the case
Xander Advisors India P. Ltd., ITA no.5840/Del./2012;
v) Dell International Service India P. Ltd., IT(TP)A no.85/
Bang./2014
case of Isro Satellite Centre 307 ITR 59 and Dell International Services (India) P. Ltd
305 ITR 37 we are of the vie v that ... also decision in the case of Yahoo India Pvt. Ltd Vs Dell (140 TTJ 195)
which has been relied upon, is certainly an authority
