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Documents citing Sas Research And Development (India) ... vs Acit, Circle-6,, Pune on 13 April, 2018

Invteva Products India Automotive ... vs Assistant Commissioner Of Income Tax ... on 18 January, 2019

For the fourth company i.e. TCE Consulting Engineers Ltd. , he placed reliance on two tribunal orders rendered in the case of Mercedes - Benz research & Development India Pvt. Ltd. vs. ACIT in IT (TP) A No. 291/Bang/2015 dated 28.04.2017 for A. Y. 2010 - 11 available on pages 1564 to 1569 of the paper book and rendered in the case of Dell International Services India Pvt. Ltd. vs. DCIT in IT (TP) A No. 85/Bang/2014 & CO No. 21/Bang/2016 dated 13.10.2017 for A. Y. 2005 - 06 available on pages 1570 to 1605 of the paper book. Regarding the request for inclusion of two companies i.e. Tata Elxsi Ltd. and Taneja Aerospace & Aviation Ltd., It is submitted that only the request for inclusion of Taneja Aerospace & Aviation Ltd. is pressed as per summary chart. This company is functionally similar but still excluded on this basis that this was not taken as comparable in the original TP study and therefore, request for inclusion at a later stage is cherry picking. Common objection about both these grounds is this that the order of DRP is cryptic. Learned DR of the revenue supported the orders of TPO/AO/DRP.
Income Tax Appellate Tribunal - Bangalore Cites 14 - Cited by 1 - Full Document

Prakash Lal Potluri, Hyderabad vs Income Tax Officer, (Int Taxn)-2,Hyd, ... on 29 February, 2024

7.1. In the absence of specific provision in the statute, the DRP voluntarily on application cannot exercise power to condone the delay in filing objections. Our above said view is also fortified by the decision of Hon'ble Madras High Court in the case of Inno Estates Private Limited Vs. DRP reported in (2015) 96 taxmann.com 646, and also by the decisions of Tribunals in the case of TDK Electronics ag formerly known as EPCOS Vs. ACIT reported in 144 ITAT 2020 (Pune) and Lam Research (India) Pvt. Ltd Vs. ACIT reported in 431 ITAT 2021 (Bangalore). In view of the above, we do not find any merit in the appeal of the assessee. Accordingly, the appeal of the assessee is dismissed.
Income Tax Appellate Tribunal - Hyderabad Cites 3 - Cited by 0 - Full Document
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